ML20197A225

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Transcript of Holtec Hi-store Consolidated Interim Storage Facility Draft EIS Public Meeting, Teleconference, July 9, 2020, Pages 1-173
ML20197A225
Person / Time
Site: HI-STORE
Issue date: 07/15/2020
From:
NRC/OCM
To:
Caverly J
References
NRC-0947
Download: ML20197A225 (177)


Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Holtec Hi-store Consolidated Interim Storage Facility Draft EIS Public Meeting Docket Number:

(n/a)

Location:

teleconference Date:

Thursday, July 9, 2020 Work Order No.:

NRC-0947 Pages 1-173 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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TO PRESENT THE RESULTS OF THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) DRAFT ENVIRONMENTAL IMPACT ANALYSIS FOR HOLTEC'S PROPOSED HI-STORE CONSOLIDATED INTERIM STORAGE FACILITY (CISF) FOR STORING SPENT NUCLEAR FUEL AND RECEIVE THE PUBLIC'S COMMENTS ON THE DRAFT REPORT

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CATEGORY 3 MEETING

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THURSDAY, JULY 9, 2020

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The Meeting convened via WebEx, at 5:00 p.m. EDT, Chip Cameron, Facilitator, presiding.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 PRESENT:

CHIP CAMERON, Facilitator JILL CAVERLY, NMSS JOSE R. CUADRADO-CARABALLO, NMSS DIANA B. DIAZ-TORO, NMSS STACEY F. IMBODEN, NMSS KELLEE L. JAMERSON, NMSS MIRIAM JUCKETT, NRR DAVID T. MCINTYRE, OPA JOHN B. MCKIRGAN, NMSS JESSIE QUINTERO, NMSS JOHN R. TAPPERT, NMSS

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P R O C E E D I N G S 5:02 p.m.

OPERATOR: Welcome and thank you for standing by. I'd like to inform all parties that your lines have been placed in a listen-only mode until the comments section of today's conference call.

I would now like to turn the meeting over to Mr. Chip Cameron. Thank you, sir, you may begin.

MR. CAMERON: Thank you, Calvin, and hello, everyone. My name is Chip Cameron and I'm going to serve as the facilitator for today's NRC public meeting.

I want to quickly go over some basics of today's meeting so that you know what to expect. And first of all, we're going to try to avoid acronyms.

I just used one, NRC, I think we all know that stands for Nuclear Regulatory Commission.

You also might hear EIS, that stands for Environmental Impact Statement, and also NEPA, that stands for National Environmental Policy Act. And that's a good lead-in to the purpose of tonight's meeting.

We're here for the NRC to listen to your comments, your concerns, your recommendations, on the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 draft EIS the NRC has prepared.

On a license application, a license application is submitted by Holtec International to construct and operate an interim storage facility for spent nuclear reactor fuel.

This facility would be located in southeastern New Mexico if the NRC licenses it. Now, the draft EIS is a key part of the NRC's evaluation of whether they grant the license to Holtec and the requirement for the NRC to evaluate the environmental impacts in an EIS comes from NEPA.

The other key component of the NRC evaluation is looking at public health and safety issues. And this requirement comes from the Atomic Energy Act, and that will be reflected in something called a Safety Evaluation Report that the NRC will prepare.

And I just want to emphasize that word, draft, in terms of the draft EIS.

The NRC will not finalize that draft EIS or use it in the decision-making on the Holtec license application until it evaluates your comments tonight at other public meetings, or comments that you submit in writing or email.

The NRC Staff is not going to be

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 responding to your comments tonight or any questions you might have in your comments, but they will carefully evaluate what you say tonight when preparing the final EIS. And they will in that document respond to your comments.

They're obligated to respond to your comments. We're in a virtual setting tonight and comments are going to come in by phone. You just heard from Calvin, he's our operator tonight and he's going to instruct you on how to sign on to speak.

We're also using Webex to show you the slides that are going to be presented tonight, and you're going to see a slide later on that's going to tell you how to see those slides, get those slides, if you have trouble getting on to Webex.

And if you do go on Webex, you're going to see a chat box, C-H-A-T. If you have any technical difficulties, if you need one of the speakers to speak more loudly, I sometimes am talking to the ceiling because I think that's where all of you are and the mics are on the desk here.

But just send that in to the chat box.

And in addition, if you have questions about the EIS process -- for example, when do you think you'll have that final EIS, NRC -- you could

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 put that question in the chat box and then we'll look at that and we'll try to answer those questions before we get off tonight.

We're going to take a break around 7:30 p.m. and that may be the first opportunity for us to answer some questions. We did learn some lessons from the last meeting we did on June 23rd, where we thought it was going to be a great idea to identify a list of speakers and call them.

But we found out there's a delay involved in doing that and also a lot of confusion about did we put someone on the list who isn't on the line?

So, tonight it's going to be basically first come, first serve, and Calvin is going to be helping us with that. But we did have a little bit of a kerfuffle or a glitch before we put out the notice that it was going to be first come first serve.

And believe me, Calvin will tell you how you do that. We had about 20 people who signed up to speak, thinking we were going to use the list again.

Well, we're not going to lose the list but for those 20 people, to be fair, I am going to, when we get to comment, call a name and Calvin is going to ask that speaker, for example, Diana Diaz-Toro, she happens to be the first one on the list.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Diana, could you press Star-one, I think it is? And he'll put Diana in.

After we hear from Diana we're going to go to the next person on the list and then when we're done with that, then Calvin is going to say if you want to get on the line, hit Star-one and he's going to keep a running list and he's going to put you on.

When you do get on, just introduce yourself and give your affiliation if you would like.

in terms of time limits, I'd like you to keep it to four minutes, keep your comments to four minutes.

We had 80 speakers last time and we were here until about 10:30 p.m. Eastern time, and so try to keep your comments to four minutes. If you get to five minutes and I apologize in advance if I have to cut you off.

I'm going to ask you to finish up right then and if I need to, I'll ask Calvin to mute your phones. So, if you know that you're going over five minutes, just try to cut that down so you meet the time limit.

I have to thank everybody from the last meeting, everybody was very courteous and basically kept to the four minutes. So, that was good and because we might have a whole lot of speakers again

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 tonight, we're going to have a list of the people who have signed up to speak.

If you want to get an approximate idea of where you are broadly, like am I going to be at 7:00 p.m. Eastern, 5:00 p.m. Mountain, or 8:00 p.m., 9:00 p.m., you could post something there and we can tell you where approximately you might be on that.

And by the way, if you do come on to speak, you can't use the speakerphone for some reason. I don't know why but you're going to have pick up the telephone and not use the speakerphone.

And we are taking a transcript and we have Sam Wojack with us who is going to be our court reporter. He's going to be taking a transcript, that'll be available in about two weeks.

We do have the transcript from the meeting on the 23rd, and again, there's going to be a slide there that's going to tell you how to get that transcript.

So, if you do end at four minutes or I cut you off at five, you can expand on your comments in writing, by email. So, the four minutes that you have serves important purposes.

It gives the NRC Staff a preview of what they might have to start thinking about evaluating in

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 terms of preparing the final EIS. And it gives people in the community who are listening what the concerns are out there.

So, even though it's four minutes, it's very important. I'm almost done, I want to introduce the NRC Staff, who is here in the room with me or on the phones, so you'll know what their role is.

And the first person I would introduce is John Tappert. He's the Director of the Rulemaking, Environmental and Financial Support Division here at NRC, and you will hear from him in a few minutes.

He's going to welcome all of you.

Diana Diaz-Toro will be on. She's the Acting Branch Chief of the Environmental Review and Materials Branch. We have Jill Caverly with us in the room, and she's going to be giving the presentation, the summary of what's in the draft EIS.

She's the senior Project Manager for the environmental review of the Holtec license application. We also have Stacey Imboden on the phone, who's the Co-Environmental Project Manager on the Environmental Impact Statement.

We also have our safety people here. I mentioned the safety evaluation report. The safety people are here listening even though this is

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 comments on the Environmental Impact Statement because they want to make sure if you raise a safety issue, they will be alerted to that.

And we have John McKirgan, he's the Chief of the Storage and Transportation Branch, and we have Jose Cuadrado, who is the Technical Project Manager, and by the way, we have Kellee Jamerson on the phone who is helping with technology issues, with Webex issues.

We also have our Senior Public Affairs Officer, Dave McIntyre, on the phone and I would just say that if there's any media people out there, please feel free to contact Dave directly.

And you can see on the screen his email address, and if someone needs to know it, just hit the chat box and we'll tell you about that.

Now, we did want to make sure we could help anybody who is a Spanish-speaking person, that we could help them if they needed it.

And our Technical PM, Jose Cuadrado, who I mentioned, is Spanish-speaking. And Jose, do you want to do your thing in terms of the Spanish for people now?

MR. CUADRADO-CARABALLO: My name is Jose Cuadrado and I will read a brief Spanish message right

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 now for any Spanish-speaking members in participation today.

Buenas tardes y bienvenidos a todos los participantes de habla hispana a esta reunion virtual. Mi nombre es Jose Cuadrado, y soy uno de los ingenieros de la Comision Reguladora Nuclear, mejor conocida como NRC por su siglas en ingles.

El proposito de esta reunion virtual es presentar las conclusiones preliminares y recibir comentarios del publico sobre el borrador de la Declaración de Impacto Ambiental sobre la Instalación para Almacenamiento de Combustible Nuclear Usado, la cual se propone construir en el Condado de Lea, en el sureste de Nuevo México.

El borrador de la Declaracion de Impacto Ambiental discute los resultados del analisis y las conclusiones de la NRC sobre los posibles efectos ambientales que pueden ocurrir por la construccion, operacion, y la decomisacion de la facilidad.

El borrador fue publicado por la NRC el 10 de marzo de este ano, y como require la Ley Federal de Politica Ambiental, nuestra agencia provee al publico la oportunidad de comentar sobre el contenido y las conclusiones del borrador. Si usted desea proveer comentarios, puede hacerlo durante esta

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 reunion. Yo soy uno de dos empleados de la NRC participando esta tarde que hablamos espanol y que pueden traducir su comentario a ingles, si asi lo desea. Usted tambien tiene la opcion de enviarnos sus comentarios por escrito a traves de correo postal, correo electronico, o a traves del portal federal de reglamentación, Regulations.Gov. La oportunidad de proveer comentarios sobre el borrador termina el 22 de septiembre de 2020.

Durante esta reunion, mis colegas de la NRC haran un corta presentacion discutiendo el proceso de evaluacion ambiental y las conclusiones a las q hemos llegado sobre los posibles efectos al ambiente. Luego de la presentacion, el publico tendra la oportunidad de hacer comentarios verbales, los cuales seran considerados por la NRC en su evaluacion.

Para su conveniencia, la NRC ha preparado una version de esta presentacion traducida al espanol. La hoja de presentacion en nuestra plataforma contiene el enlace para descargar una copia de esta presentacion en espanol. Si usted tiene alguna pregunta sobre como accessar o descargar estos materiales, puede enviarla a traves del encasillado de preguntas (Q&A) en la plataforma

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 WebEx.

Muchas gracias por su participacion.

MR. CAMERON: I'm going to go to John Tappert, he's our senior NRC official. He is the Division Director for where the Environmental Impact Statement is being prepared.

John?

MR. TAPPERT: Thank you, Chip. And welcome and thank you all for attending this webinar.

As Chip said, My name is John Tappert and I'm the Director for the Division of Rulemaking, Environmental, and Financial Support, which is the group responsible for the development of the draft of the Environmental Impact Statement.

That is the subject of today's meeting.

The draft EIS is the result of the NRC Staff's evaluation of the environmental impacts associated with Holtec International's proposal to construct and operate an interim storage facility.

Tonight we are asking for your comments on that report. It's important to note that any comments received in this webinar forum are handled in the same manner as those comments received at an in-person meeting.

Your comments presented here tonight are

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 recorded and transcribed. My Staff will review and analyze them and will update the final EIS report as appropriate.

Comments received during this webinar will be made available in a transcript of tonight's meeting that will be posted to the NRC's Holtec review website shortly after this meeting.

Again, thank you for your time this evening and I'll turn it over to Jill to present the NRC Staff draft EIS results.

MR. CAMERON: And I would just add one thing. Joe's presentation tonight and the slides are going to be the same as were given on the 23rd.

And we always learn new things and think of new things when we hear the presentation again, even if it's the same presentation.

But I just wanted to tell you that if you need to take a break at any time during this, it's the same as we had last time.

Jill?

MS. CAVERLY: That's right, thanks, Chip. Let's go to the meeting overview slide. Okay, great, so thanks for joining us today.

Today we're here to collect your comments on the NRC's draft Environmental Impact Statement so

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the majority of the evening will be dedicated to that activity.

As Chip mentioned, I have a short presentation and I'll try to go quickly because I know really the emphasis is to get your comments on the record.

However, I will begin with an overview of the application process, including the differences between the environmental review and the safety review.

I'll move on to an overview of the applications submitted to the NRC, and then I'll summarize the results of the NRC's Staff analysis.

I'll cover some of the public comments received during scoping and the NRC's environmental evaluation results.

Finally, I'll end with information on how you can access the report and make comments on the draft Environmental Impact Statement. As I go through the presentation, I'll use the term facility and proposed project interchangeably.

The abbreviation,

CISF, stands for consolidated interim storage facility. I may also interchange Applicant with Holtec, and that's short for Holtec International.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The Environmental Impact Statement will be abbreviated to EIS, and finally, when I refer to Staff and NRC Staff, that's referring to those of us that are Staff for the Nuclear Regulatory Commission.

Next slide, please. So, what is the purpose of tonight's meeting? It's to receive your comments on the draft Environmental Impact Statement or EIS for a consolidated interim storage facility.

NRC is requesting that you review the draft EIS document and provide comments that are pertinent to the current licensing actions and the draft EIS report.

You have access to the report at the NRC's website, where it can be downloaded and read.

There are also going to be three ways for you to comment, either by email, you can go to the regs.gov website, or by regular mail.

So, the information and the message on how to comment will be summarized at the end of my presentation.

I also want to let you know that any comments you make tonight will be recorded by a court reporter and will be entered into the public docket for this licensing action.

All right, we'll go down to the next

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 slide. So, we're going to just do a quick overview of the NRC's process for a license application review. Go to the next slide? Okay, great.

So, I'd like to clarify the NRC's role as an independent regulator. The NRC determines whether to build and operate storage facility at the proposed site, Lea County, New Mexico.

The NRC evaluates the application for the facility and determines if a license can be issued.

The NRC does not promote or build nuclear facilities.

The NRC doesn't own or operate nuclear facilities.

Again, our mission and our regulations are designed to protect the public workers and the environment.

Holtec International, or the Applicant for this project, has proposed the location of the interim storage facility and Staff at the NRC will perform both a safety evaluation and an environmental review.

All right, next slide, please. So, this might seem like a familiar slide to you if you were at the scoping meeting in 2018. It's a schematic of the NRC's licensing decision process.

It appears to show you that the NRC has current reviews occurring during its evaluation

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 process. You can see from the slides that the process of licensing is based on three foundational activities, an environmental review, a safety review, and then adjudicatory process.

So, if we look on the left, the safety review will result in a safety evaluation report and that report shows the Staff analysis. And that analysis is based on the Atomic Energy Act and regulations in the code of federal regulations.

These regulations must be met in order for the license to be granted. If you flip over to the other side, the environmental review results in an Environmental Impact Statement.

And that action is taken because issuing a license is considered a federal action under NEPA, which is the National Environmental Policy Act. NEPA requires federal agencies to evaluate and disclose environmental impacts of federal action.

And then you'll see in the middle the adjudication -- I always catch on that word -- process that can be used for dispute.

Okay, let's go on to the next slide. So, we're going to delve into the safety review a little bit more, and this slide shows you many of the areas that our colleagues in the Safety Review Group look

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 at.

And NRC is required to look at these areas to assure that a design can be constructed and operated while protecting human health.

The NRC Staff will evaluate the design of a CISF and the characteristics of the construction of the site to ensure that it will be built and operated safely, that it will protect public health and safety.

The Staff will evaluate the physical security practices to assure the facility is protected from intrusions, cracks, and sabotage.

The design of the structure at the facility is evaluated to verify its integrity and ability to withstand accidents. Other areas, such as financial qualification reviews, are to ensure that it meets NRC standards before a facility can be licensed.

So, finally, the Staff will evaluate the facilities capable of withstanding external hazards, which can include temperature extremes, floods, tornados, and earthquakes.

So, the safety evaluation determines whether a facility can be constructed and operated to protect human health.

And you could say that the safety review,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in part, evaluates how the environment will impact the design and whether that design is capable of providing the protection for safely storing spent fuel.

We'll go onto the next slide. So, on the other

hand, the parallel environmental review evaluates what the project will do to the environment.

The environmental review starts with the current environmental condition at the state line and so in the EIS we call this the affected environment. So, for each of the resources you see listed here, we will evaluate the impacts to that baseline.

Using the baseline data, the Staff will evaluate the changes or the impacts to each of the listed resource areas, should the facility be constructed and operated.

So, that delta or the change to the resource is evaluated and that change is called the impact to the resource. And that's disclosed in the Environmental Impact Statement.

All right, next slide, please. So, here, the NRC wanted to quantify the impacts and uses the definitions listed here for significant levels of environmental impact.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So, you can see it's small, moderate, and large, and the scale rises based on the destabilizing influence of the resource. So, these definitions are also found in NRC Staff guidance.

All right, let's move on. Now we're going to get a little bit more into the details of the application. So, let's move on to the next slide.

So, the proposed project is located halfway between the towns Carlsbad and Hobbs in New Mexico, and the CISF project includes storage facilities, related buildings, and a rail line.

So, the portion of the rail line which is shown in the diagram on the right, which is part of that little curly cue. And the rail line continues off of this diagram on the right and will go south off the diagram, and then go west five miles to tie into an existing rail line.

The area of the rail line that is on the Southern side of this diagram and moves over to the west is on land that's owned by the Bureau of Land Management. Holtec is seeking a permit for that action.

So, the Bureau of Land Management is a cooperating Agency with the NRC on the development of the CISF. In addition, the New Mexico Environment

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Department worked at the cooperating agency with NRC on surface and groundwater resources.

Next slide, please. So, here on the left you have an artist rendering of the proposed action and the project diagram on the right, if you look at these two together, the proposed project is on the left and the area circled in red on the right diagram is also representing the proposed project.

So, if licensed, Holtec would be granted a license to build and store 500 canisters of spent fuel.

So, Holtec has stated its intention to apply for amendments to the license for up to 20 phases, which is represented by the rest of the black rectangles on the diagram.

So, full build out for all 20 phases, the area covered would be approximately 330 acres. NRC would perform those safety and environmental reviews for any additional amendments.

Let's go to the next slide. So, as I mentioned, the proposed project would be an in-ground, low-profile design. On the right side is a photograph of a similar design used for spent fuel storage.

The proposed project would use what's

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 called the HI-STORM UMAX system for storage of spent fuel. And the HI-STORM UMAX stands for Holtec International Storage Module Underground Maximum Capacity System.

And each of these modules holds one canister of spent fuel.

Next slide? Okay, so to give you some perspective. We are looking again at an artist's rendering of Phase 1 on the right or the proposed license project.

This would include the 500 canisters of spent fuel stored in an underground system using the UMAX canister. On the left is a picture of the UMAX canister, which is an engineered canister designed to passively cool and store spent fuel for long periods of time.

It's constructed from stainless steel and has been certified by the NRC for storage of spent fuel at power reactor sites. So, that means that the manufacturing and design of the canister is engineered to meet NRC requirements for safety.

Those include structural integrity, material integrity, and longevity. The canisters contain spent fuel rods so there's no liquid inside these canisters.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The thickness and the internal characteristics are designed to prevent radioactive material from escaping under normal and accident scenarios. And that's achieved by using redundant welded seals and robust structural design.

The CISF design which is being proposed in the current license application will store the UMAX canister for a license term of 40 years. That means the NRC is currently evaluating the design of the facility to ensure that that facility meets those requirements.

That was a slide to help out with the clarification of the EIS and how the Staff evaluated it. And as I mentioned earlier, the proposed action is Phase 1 or 500 canisters of spent fuel.

I also stated earlier the Applicant has made it known to the NRC that it has the intention to request up to 19 additional phases for license amendments.

So, those are referred to in the EIS as full build out, or Phases 2 through 20.

The Staff in its discretion evaluated all 20 phases of the project in the environmental impact phase. So, it's important to understand that the NRC is not licensing all 20 phases.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The decision to evaluate all 20 phases was made by the NRC Staff to provide additional perspectives of the environmental impact.

So, finally, Staff evaluated the project in phases. So, we have 20 phases of the project and then we have an evaluation of stages, and those stages are construction, operation, and decommissioning.

So, we did that because each of these stages for each phase has unique environmental impacts.

When appropriate, the Staff evaluated the maximum impact for combined stages for different phases in the process.

So, it sounds confusing, but for example, the Staff may have evaluate the construction stage for Phase 2 in conjunction with the operation stage for Phase 1 because this was represent a peak impact.

Okay, so we're going to move on and talk about the public scoping comments a little bit.

We'll move on to the next slide.

Okay, so many of you might have remembered that we had an open scoping period in 2018 where the Staff came out and held several meetings in areas around New Mexico.

We received quite a

few comments correspondence and we received 3900 unique comments.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So, if you'd like to look into that a little bit more you can find the scoping summary report at this address right here.

Next slide, please. So, during the scoping period we received quite a few comments on transportation, location and land use, geology, the volume, water, socioeconomics, external events, that's all located in our report.

But what I wanted you to look at closer was on the right side, which is the out of scope comment.

So, many of the comments that we received on potential flooding, upstream hazards, the UMAX system, financial assurance, those were considered out of scope for the EIS but you can see now from the discussion earlier that those are safety review requirements.

So, those will be evaluated within the safety review. Let's move on. We'll go to the results of the NRC review and we'll go to the next slide. Okay, so let's talk a little bit about the impact evaluation, the results of the EIS.

So, the Staff evaluated a 40-year license term and the spent fuel would be removed before any decommissioning stage would begin.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The Staff impact evaluation characterized the groundwater of the facility and evaluated forced water overflow and run-offs nearby fires or lakes.

Next slide? So, for transportation accidents, the Staff evaluated traffic and road degradations to workers and construction vehicles during all stages and all phases of the project.

Staff evaluated the movement of the entire 20 phases of material or 10,000 canisters using conservative representative routes.

The radiological dose and the health effect to the public and workers along the routes were conservatively estimated and found to be low relative to background radiation and effective baseline cancer risk.

Impacts from transportation accidents were evaluated as the doses to first responders, workers, and members of the public.

The NRC's rules require spent fuel transportation canisters to withstand severe accident conditions, so an assumption of no releases during accidents was used in the Staff analysis.

Previous NRC technical analysis involving spent fuel and canisters support the no-

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 release assumption.

The location of the facility was proposed by the Applicant but the NRC Staff did evaluate the Applicant site collection process but for land use the Staff evaluated a six-mile radius of that facility.

Let's move on, next slide, please.

Okay, so for environmental justice, or what we call EJ, the impact evaluated the impact on human health and the environment using many well-known guidance documents, including council and environmental equality, federal interagency working group on environmental justice, and NRC's guidance and policy statements.

The region of influence for the analysis included 115 block routes which are geographic areas that include between 600 and 3000 people, and within 10 counties that falls completely or partially within a 50-mile radius of the proposed CISF project.

Staff identified potentially affected minority or low-income populations and performed the relevant comparisons to the broader geographic regions.

The socioeconomic impacts were evaluated based on workers, past revenues, and resource

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 availability for the community.

Past revenues and economic growth from the proposed project and from the additional workers in the area were evaluated for impacts, including the use of public services, schools, housing demand due to that increased population.

Okay, let's move to the next slide. So, we're on the home stretch here. So, here is the tabulated results of the Staff's review for all the different resources.

And as you see, we've broken them out into the proposed action and additional phases. So, Phase 1 and Phase 2 through 20, you can see the results there. And on the side is the significance level.

We'll move on to the next slide and that's just a continuation of the results. If you look at Chapter 9, the summary of environmental consequences, it gives a nice summary and then we'll move on.

So, here's a good slide for everyone.

This is information resources. The draft and Environmental Impact Statement address is right there, I'd also like to point out we had readers guides in both Spanish and English.

It's a 20-page summary in plain language

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and explains the Staff's review and results, and the last bullet there is a site that you should go to for all the material on this project.

If you go to that last address, the one that says spent-fuel-CISF-Holtec-International, you will get a lot of information.

If you scroll down to the bottom of that page, you'll get all of the presentations for the last meeting, the presentations for today's meeting in both Spanish and English, and also the transcript.

So, the transcripts from the last meeting are already up there on that site, and the transcripts for tonight's meeting will be on that site very soon.

Okay, let's go to the next slide. Okay, so how to comment.

As I mentioned before, you can go to the federal rulemaking webpage, which is regulations.gov, you can send them through regular mail and there's an address for our Office of Administration.

And you can email to the email address listed on the slides at the last bullet. And of course, any of the comments that we receive today will be transcribed and docketed and reviewed for inclusion into our final report.

So, I think if we go to the next slide,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I think that's the end. So, I'm going to turn it over to Chip and we can get started on the comments.

MR. CAMERON: Thank you, thank you very much, Jill. And Calvin, are you ready?

OPERATOR: Yes, sir.

MR. CAMERON: Okay.

OPERATOR: Go ahead, sir.

MR. CAMERON: Could you see if Diane D'Arrigo -- could you put Diane D'Arrigo on?

OPERATOR: Thank you. Diane D'Arrigo, if you can hear me, please press Star-one and I can open your line. That's Star-one.

MR. CAMERON: Okay, Calvin, I think we'll see if Diane can catch up to us later during the first come first serve. So, let's see if State Senator Gay Kernan is on.

Could you open up Gay's line?

OPERATOR: Yes, one moment. Your line is now open, Ms. Kernan.

SENATOR KERNAN: Yes, Can you hear me?

MR. CAMERON: Yes.

SENATOR KERNAN: Yes, I am New Mexico's State Senator, Gay G. Kernan, representing District 42, which includes Lee and Eddy Counties.

I serve on the Interim Radioactive and

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Hazardous Materials Committee and have had the opportunity to receive information regarding the proposed interim storage facility in Lee County.

I have previously testified in support of the project and for Holtec as the licensee. This support has been contingent upon the findings of the NRC, as it relates to the environmental impact to our region.

I have reviewed the draft Environmental Impact Statement on the Holtec project.

I believe that the NRC Staff was committed to engaging experts in the areas of waste management, water resources, nuclear engineering, environmental sciences, geology, climatology, and agricultural engineering, all of whom contributed to the document before us.

The work of the experts was thorough and presented in detail many of the issues that must be addressed when determining whether to grant Holtec a license to build and operate an interim facility in Lee County.

I'm of the opinion that the work of the NRC Staff confirms that this facility can provide a safe alternative for the interim storage of spent nuclear fuel.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I believe further conversation should be occur with regards to the issue of continued oil and gas production, high-risk mining, and an update on the flow of work force to the site as the oil and gas industry rebounds. I represent the citizens of Lee and Eddy County.

The educated opinion of my community is important. The benefit of this project to those I represent, both locally and from a state perspective must be weighed and factored into any decision we make.

All New Mexicans must understand the need for diversification in our state and every opportunity must be thoroughly vetted and seriously considered.

The draft and Environmental Impact Statement released by the NRC provides that first step to diversification.

And that concludes my comments.

MR. CAMERON: Thank you, thank you very much for those comments, Senator. Calvin, can you see if Adrian Shelley is on?

OPERATOR: Adrian Shelley, please press Star-zero. One moment please.

MR. CAMERON: Okay, we'll see if Adrian catches up with us later and let's see if counselor

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Wes Carter is with us. Can you see if Wes Carter is there, Calvin?

OPERATOR: Thank you. Wes Carter, please press Star-zero. One moment and we'll have the signal coming in. I don't have Wes Carter but I do have Diane signaling.

MR. CAMERON: Oh, good, put Diane on, please. Thank you.

MS. D'ARRIGO: Hello?

MR. CAMERON: Hi Diane.

MS. D'ARRIGO: Hi, this is Diana D'Arrigo.

I'm with nuclear information and resource service and I will keep it short since I did have an opportunity to make some points on the previous call.

I hope that especially local residents and people who were not able to speak last time get a chance to this time.

I see that you've got a Spanish speaker there that will be able to have people that do speak Spanish to realize that they've got this opportunity to have things translated.

And the first thing I want to say about the whole licensing process for the proposed consolidated storage facility is that it is not

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 legal.

It's not legal on a national level under the Nuclear Waste Policy Act and, of course, as we both were tracking it no, the interventions are now moving into the court system to challenge that.

And also, there's the question about the legality on the local level, on the interactions that took place between Eddy, Lee, Energy Alliance, and Holtec.

And the questions have not been brought to the fore but I think it's incumbent on the Nuclear Regulatory Commission to look into any local improprieties that may have taken place.

Also, the Environmental Impact Statement is segmented and is not comprehensive, it's not looking at all of the impacts in conjunction with each other.

This project is actually the pinnacle of dangerous reactivity affecting the entire country by moving such a massive amount of radioactive material, manmade radioactivity, from various places all around the country through communities and farmland.

And the Environmental Impact Statement is not adequately addressing or notifying and getting input from people all along the routes.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So, we have called for and continue to call for an extension on the comment period until after the COVID crisis, six months after, and then when safe, to hold public meetings, DEIS meetings, in as many communities as possible throughout the country that we'll have multiple shipments coming through of the hottest radioactive material in the world.

So, that's a

segmentation by not including that part of the impact in the final decision and to declare that to be small is inadequate and incorrect.

Finally, we have a danger when consolidating irradiated fuel of reprocessing, and it is incumbent to look at what the effects have been of reprocessing on communities in at least four, maybe five states in this country, where reprocessing waste still plagues the communities, threatens the water ways, is actually leaking into some of them, and has not been made safe from the reprocessing that has already taken place in the public and private sectors.

So, to talk about consolidating fuel, which is Step 2, to reprocessing, it needs to be included in the potential consequences of such activity in the analysis.

I will stop there and repeat the call for

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 an extension on the comment periods and the public meetings, and the information available in Spanish, comprehensively looking at all of the pieces of what the Holtec project would do.

And of course, face the illegality of the entire project.

MR. CAMERON: Thank you, Diane. Calvin, could you see if Susan Crockett is available?

OPERATOR: Susan Crockett, please press Star-zero. One moment please.

MR. CAMERON: Is it Star-one?

OPERATOR: Ms. Crockett, your line is open.

MR. CAMERON: Calvin?

OPERATOR: Yes?

MR. MARFORD: Sean Marford, how are you doing? Am I on?

MR. CAMERON: Excuse me, this is Chip.

I want to check in with Calvin. Calvin, did you find Susan Crockett?

OPERATOR: I asked for her to press Star-zero and the line did signal now open, that line.

But I don't believe it was her.

MR. MARFORD: Well, I'll go ahead and speak.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Sir, could you identify yourself again?

MR. MARFORD: My name is Sean Marford and they call us the Navajo people. We're aboriginal people, we're indigenous people on this land.

And we heard that you're thinking of bringing some nuclear waste to our area here and we have to object to that. When you all came as newcomers to this land long over 500 years ago, you came with your own ideas and your own ways.

You were refugees at that time and now we're at the point where you've gone too far. You haven't lived in harmony with this environment that we have as indigenous people here.

You're going to against the rules of the nature, the mother earth, the father sky, and as Diane said previously, two calls ago, she represents the New Mexico people but as indigenous people we represent the earth and the future of all life.

We go beyond just New Mexico, we speak for the whole creation, God's creation. And for her to accept this project just tells me it's about money, but that's not how we are as indigenous people.

We're here about surviving into the future and so what you all are doing is not

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 appropriate, it's not right, and you shouldn't be bringing your waste to our territories here. And so I know the COVID virus is presenting this.

Chip and Calvin, we don't even know if you're a real person. You could be an AI for all we know in this day and age. So, before we even move forward, we need to sit down and see each other face to face.

We need to see your little eyes and ears and all those things to make sure you're a human being, that we're actually talking to somebody that has a heart and a spirit, a mind, so we can begin to talk some sense into them that they don't bring all this manmade destructive material to our land.

We have to protect our waters, we have to protect the animals, the insects, the rocks, the plants, everything.

And we're really concerned about this so you need to step back, you need to wait until there's some sort of resolution with this COVID-19.

And then when we can sit down in the same place, face to face, eye to eye, breast to breast, and we can talk about these things because what you all are planning is one of the most dangerous things ever to come around. And you guys are trying to do

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 it over the phone.

It's unacceptable.

And all your presentations sound beautiful, oh, we've got this covered, the stainless steel, but we know that's not true, you're just highlighting what you can control.

But the part of it you can't control is what's going to happen with mother nature. And so we have to step back, you guys need to sit down with us face to face, and then we have to talk about how we're going to get out of this mess that you created with nuclear energy.

We told you a long time ago, before you even started it, not to go down that road and when Fukushima went, March 11, 2011, the elders and the medicine people and they got together and they made a very strong statement against that because what you are doing, we told you a long time ago, you're creating things that you can't even control.

And I think your pain right now is feeling that, as they're trying to figure out what to do with all that water and all those rods that are laying around and they can't control it.

And you all need to take a step back and you need to include us as indigenous people from the very beginning. We should have been the first ones

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to talk on this line, not what Chip has orchestrated here, saying, oh, this person can go, that person can go.

That's orchestrating what you want to see and who you want to see on the line. And that's not appropriate.

That's what happens when you do things by the telephone, you get one guy like Chip that's going to control the whole thing and no one else gets a voice in this situation, except for if it's dictated by him.

We need to sit down face to face, eye to eye. Remember, you're newcomers here and you're destroying the territory. As the elders had said, you came here and you said, oh, what a paradise.

Well, you're destroying our paradise and you're affecting the future of life.

MR. CAMERON: Thank you for your comments.

MR. MARFORD: I'm going to say that much, Chip, and as I said, you need to quit orchestrating this and you need to sit down with us.

MR. CAMERON: We'd like nothing better than to sit down face to face and listen to you.

MR. MARFORD: Well, let's do it. You

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 need to stop what you're doing and let's do it.

MR. CAMERON: Okay, thank you.

MR. MARFORD: Thank you.

MR. CAMERON: You're welcome. Calvin, did you ever confirm if Susan Crockett is there?

OPERATOR: She is not, no.

MR.

CAMERON:

How about Katherine Cumbow?

OPERATOR: Katherine Cumbow, please press star-zero. One moment please. One moment.

MR. CAMERON: Calvin, McMurrian is there if Katherine Cumbow is not.

OPERATOR: Someone queued up and said her name was Katherine Scopic.

MR. CAMERON: Katherine Scopic? Well, if there's someone cued up, put her on.

OPERATOR: Thank you.

(Simultaneous Speaking.)

The line is open.

MS. SCOPIC: Can you hear me?

MR. CAMERON: Yes.

MS. SCOPIC: Okay, hi. Yes, my name is Katherine Scopic, I'm speaking to you from New York City and I thank you for this opportunity to speak to this issue of consolidated interim storage facility.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 From a moral standpoint, this whole idea is wrong. I agree with the Native speaker, the Dine speaker, who just went.

I would also say that the entire premise, before you get into the details of the EIS and the health and the environmental impacts, the whole premise is incorrect.

I don't know about you but myself and most of my colleagues and everybody I know was brought up by their

parents, their
teachers, their communities, to clean up their own mess.

It's a value, it's a way of living, if one makes a mess, you clean it up. That's part of the value that I was brought up with, thanks to my parents, my teachers, my community, my religious faith leaders.

And each of us is responsible for what we do, we cannot give it off to somebody else. So this whole premise is incorrect because the nuclear energy that was created by these fuel rods, by this uranium, was benefitting people in specific communities.

And now that fuel is no longer useable, the premise is to ship it somewhere else, to some other community, to some other location. Some location that has nothing to do with the nuclear

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 energy plant in the first place.

People who did not receive benefit from this fuel. So the whole premise is incorrect and going even beyond that, the fact that our whole mother earth cannot deal with this, these materials will be toxic, will be radiated for thousands of years.

We had a presentation just the other day and someone came across the symbol that the United Nations was trying to come up with to show people in future generations that there was danger buried there, there was danger buried there.

How are we going to let generations after us, were this to occur, were these storage facilities to go forward, how do we let generations in the future know that what is buried there or what is contained in these canisters is toxic and can kill people?

And they came up with a red triangle with a person running and a sign of a skull to show that this is danger. So, we know that what we're dealing with is dangerous and, yes, people have created it.

And to just pass it off to another community in another state where there is more open space is wrong.

And I just want to say that not only is it wrong from a moral standpoint, from the indigenous

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 standpoint, it is also illegal, as Diane pointed out.

And Diane has been working with us for a long time and they've been working on this issue.

So, I just think it's a strike out that's two strikes, you're out. You're out from a moral standpoint, from an indigenous standpoint, and from a legal standpoint.

So, that's all I have to say.

MR. CAMERON: Thank you, Katherine. And Calvin, can you see if Katrina McMurrian is there?

OPERATOR:

Thank you.

Katrina McMurrian, please press Star-zero. One moment.

MR. CAMERON: Calvin, let's see if Senator Richard Martinez is there? I think the Senator should be there --

MS. MCMURRIAN: This is Katrina.

MR. CAMERON: Oh, is this Katrina?

MS. MCMURRIAN: This is she.

MR. CAMERON: Katrina, go ahead.

MS. MCMURRIAN: I'll just say, many of our members are interested in this and other matters concerning consolidated interim storage.

We'll forgo such comments at this time and submit written comments for the record but we'll just say thanks to the NRC team and you, Chip, for

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 this opportunity and all the hard work that went into the draft EIS.

So, thank you for that.

MR. CAMERON: Thank you very much for that, Katrina.

MS. MCMURRIAN: I should have said on behalf of the Nuclear Waste Strategy Coalition.

MR.

CAMERON:

Okay, Nuclear Waste Strategy Coalition.

MS. MCMURRIAN: That's it, thank you.

MR. CAMERON: You're welcome. Calvin, can you see if Senator Martinez is available?

OPERATOR: Senator Richard Martinez, please press Star-zero. I'm not getting a response.

MR.

CAMERON:

Okay, let's try representative Phelps Anderson. Can you see if Phelps Anderson is on?

OPERATOR: Phelps Anderson, please press Star-zero.

MR. CAMERON: No luck there, Calvin?

OPERATOR: No, sir, I'm not getting a response.

MR. CAMERON: Okay, I'm just going to ask you to see if Senator Ron Griggs is there? He would be Number 18.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 OPERATOR: Mr. Griggs, please press Star-zero. Mr. Ron Griggs? Please press Star-zero.

One moment please. Mr. Griggs, your line is open.

SENATOR GRIGGS: Thank you. This is State Senator Ron Griggs. I represent portions of Carlsbad and Eddy County. My senate district is 34.

I participated in many meetings concerning the Holtec project and it's my take that the residents of Lee and Eddy County believe the project will be beneficial to their area.

They believe that the risks have been sufficiently mitigated and that the project is safe for them and for New Mexico.

They believe Holtec will be a good partner for the area and has worked diligently to provide all of the information needed to show the safety of the particular approach they intend to use.

If questions and concerns still exist, I've been assured that Holtec and the NRC will do their best to address them to everyone's satisfaction.

The NRC's rigorous process, I believe, will ensure that Holtec will protect the area and the state, and I appreciate all the hard work that's gone into developing the project and to researching the impacts it'll cause.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So, thank you and again, this is State Senator Ron Griggs.

MR. CAMERON: Thanks a lot, Senator Griggs. Calvin, can you see if Louise Jensen is there?

OPERATOR: Yes, one moment, please.

Louise Jensen, would you please press Star-zero? I'm getting no response.

MR. CAMERON: Okay, how about Marilyn Lohr? Marilyn Lohr?

OPERATOR: Marilyn Lohr, please press Star-zero? One moment please. No response from Marilyn Lohr.

MR. CAMERON: Okay, could you try Representative Jim Townsend?

OPERATOR: Mr. Townsend, please press Star-zero.

(Simultaneous Speaking.)

MR. CAMERON: Do you have someone?

OPERATOR: No, sir, I did not get a reply.

MR. CAMERON: Let's try Cindy Rae, R-A-E.

OPERATOR: Cindy Rae, please press Star-zero. One moment please. I have no response from

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Cindy Rae.

MR. CAMERON: Let's see if Leona Morgan is with us now.

OPERATOR: Thank you. Leona Morgan, please press Star-zero, again that's Star-zero.

MR. CAMERON: Calvin, let's see if Councillor --

(Simultaneous Speaking.)

OPERATOR: Ms. Morgan?

MR. CAMERON: Okay, good. Go ahead, Leona.

MS. MORGAN: Okay, thanks Chip. So, I already commented last time and will be submitting more substantive comments in writing.

I'm with the Nuclear Issues Study Group and like the speaker before, I am also Dine and representing the people who will be impacted, the indigenous people who will be impacted if this proposal were to go forward.

And I just want to point out that the draft Environmental Impact Statement is quite inadequate.

There's a lot of things it does not cover and we should not even be having these hearings until the draft and Environmental Impact Statement covers

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a lot of the stuff that it left out.

And I think it's inaccurate as well.

Some of the findings that the impacts are small or there's no impact at all are completely untrue, as you will hear throughout the rest of this call.

I also want to speak to the idea that this is creating economic diversity. This is something we heard a lot on the last call on June 23rd. I think New Mexicans would be in favor of economic diversity, meaning not investing in nuclear projects.

We have enough already. What we need to invest in is clean-ups from all of those nuclear projects, especially the abandoned uranium mines and the contamination left from the Manhattan Project.

And so I'd like to speak directly to those representatives and senators from New Mexico who tried to push this forward back in 2016 by passing memorials in the state when the application was not even made public. And much of it had been redacted.

So, we at the Nuclear Issues Study Group oppose this project.

I as an individual, along with speaking on behalf of the resolutions that were passed in our communities, we have a couple resolutions from the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Navajo nation, as well as the All Pueblo Council of Governors, which represents the 20 indigenous nations in New Mexico that have all spoken out against this project.

And so I will just make my comments brief because I know there is a lot more people you will hear from.

So, we oppose the project but I guess we would support a no-alternative, we would support no EIS alternative is what I want to say.

Thank you, Chip, and thank you for having this meeting. We will request that you hold in-person meetings at the time when a vaccine is available. Thank you.

MR. CAMERON: Thank you, Leona, for those comments. I want to see, Calvin, is J.J. Chavez there? Did you try him?

OPERATOR: Yes Jason Chavez, your line is open.

COUNCIL MEMBER CHAVEZ: Hello?

MR. CAMERON: Yes?

COUNCIL MEMBER CHAVEZ: My name is J.J.

Chavez, City Councillor for City of Carlsbad, New Mexico. Thank you for having this second meeting and allowing me the opportunity to comment.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The current crisis gripping the nation is hurting New Mexico's oil and gas industry, which is why we need to fall back on diversity in southeast New Mexico.

The proposed Holtec project for Lee County, both for fossil fuels and the nuclear industry to work side by side in providing jobs and revenue security for the state.

I've known about Holtec for a while and they appear to be a very worthy company. We look forward to our community having reliable jobs for years to come.

I stand in support of the project and urge the NRC to fully grant the license to operate.

Thank you.

MR. CAMERON: Thank you very much, Councillor Chavez. And let's see if Councillor Leo Estrada is with us, Calvin.

Leo Estrada, E-S-T-R-A-D-A.

OPERATOR: Thank you. Leo Estrada, please press Star-zero, again that's Star-zero. One moment please.

MR. CAMERON: Okay, Calvin, it doesn't look like we're getting any response there. Let me try Senator Stuart Ingle, I-N-G-L-E. Stuart Ingle.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 OPERATOR: Stuart Ingle, please press Star-zero, again that's Star-zero. One moment please.

MR. CAMERON: Okay, Calvin, let's see if Chris --

MS. RAE: Hello?

MR. CAMERON: Who is that?

MS. RAE: This is Cynthia Wheeler or Cindy Rae. Can you hear me?

MR. CAMERON: Oh, it's Cindy Rae?

MS. WHEELER: Yes, Cynthia Wheeler. Can you hear me?

MR. CAMERON: Yes, we can, go ahead.

MS. WHEELER: It was very hard to get on.

I've been trying to get on since my name was called so I'm assuming other people are having the same issue.

This is Cindy Wheeler, I live in Santa Fe and grew up in Roswell. First, we agree that this is a local issue but the only locals we heard from in the first hearing were officials and businessmen.

The NRC has done no outreach to make sure the community is aware of both sides of the issue and that is why the NRC doesn't know how most of the local residents feel about this project.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Secondly, this is not a local issue. At-risk people all along the transportation chain have standing as locals because they are in the cross-hairs of one unexpected accident and health catastrophe.

Again, the NRC has done no outreach to residents in the states the way full travel through and has refused to hold hearings in them.

Third, I'd like to correct some misconceptions from the last webinar. From those local officials and businessmen who commented, we even had some today, none of whom are nuclear physicists, radiologists, or systems analysts.

Sam Cobb told us the cask designs are robust and safe, and Holtec has the best operational expertise in the world.

If the NRC's own canister safety specialist describes Holtec's design as using the same kind of thinking that led to the NASA space shuttle disaster, John Heaton assured us that we have found Holtec to be absolutely ethical and honest.

Yet ProPublica has found that Holtec has been fined for bribery and for doing business with governmental agencies and lied about it.

Jack Volpato stated that Holtec was leaps

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and bounds better than anyone else we interviewed to do this project with us. However, there's some evidence that the only bid offered and the only interview granted was from Holtec.

Senator Fulfer told us the handling of high-level spent nuclear fuel is, quote, one of the most benign parts of the cycles of nuclear energy, unquote.

Contrast that with the Union of Concerned Scientists that report spent fuel is more radioactive than the fuel rods in the reactor and is the most dangerous part of the cycle. Fear was a popular charge.

Opponents were called emotional and creating misinformation by Georges Scott, told that their fear is not factually based by Sam Cobb and Wes Carter.

Mark Walterscheid accused people from other parts of the country of fearing the very idea of nuclear, and Mayor Janway believes that fear and politics can't coincide with science. Actually, fear can be due to facts as well as falsehoods.

Frankly, if you are not afraid of the effects of radioactive, you are not courageous but gullible. Council Member Edward Rodriguez believes

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that the minority reports but the majority rules.

This statement is dismissive and unjust.

Those experiencing the most risk deserve the most input, forget the numbers.

Finally, we heard that becoming a nuclear waste dump is necessary for a diverse economy from Ernie Carlson, Jonathan Sena, and Senator Minounos.

But the choice is not binary, that we either welcome becoming a nuclear waste dump or suffer a weak economy.

This is not true, but even if it were, it's a false equivalency. It assumes that a diverse economy is as important as people's health, safety, and land.

Land that does not become a wasteland of radiotoxins will provide for humans for millennia.

Land that is contaminated with eternal toxicity provides for no one and is sacrificed forever.

Is there time for me to make one further quick statement?

MR. CAMERON: Go ahead.

MS. WHEELER: Thank you. For those who think this project is a guaranteed slam-dunk to a robust economy, I have one word, Fukushima.

The official cost projection in 2016 was

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 updated to more than $202.5 billion. And some estimates are three times higher. In all these shipments across all these states, only a credulous fool will think that an accident won't happen.

We do not think these businessmen and officials are credulous fools. We think they are betting that an accident won't happen until they've made their profits and disappeared.

Thank you for the opportunity.

MR. CAMERON: Thank you, Cindy Rae. And we're going to go to Mark Richter and Barbara Warren, and then we're done with the list and we're just going to let you control who comes on.

This may get more efficient and people who call who weren't there, if they want to come on through the first come first serve, they can do that.

Can you see if Mark Richter is there?

OPERATOR: Thank you. Mark Richter, please press Star-zero. Again, Mark Richter, please press Star-zero.

Mr. Richter, your line is open.

MR.

RICHTER:

Thank you.

Good afternoon, this is Mark Richter.

I'm a senior Project Manager for the Nuclear Energy Institute in Washington D.C. and I'd

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 first like to start by offering my thanks and appreciation on behalf of NEI and the industry for the opportunity to offer some comments this afternoon regarding the NRC's draft Environmental Impact Statement for Holtec's consolidated interim storage facility license application.

The Environmental Impact Statement documents the NRC's thorough independent evaluation of the significance of the potential environmental impacts of the proposed action, that being the consolidated interim storage facility and reasonable alternatives to that proposed action.

NEI provided comments at the June 23rd event and those comments were focused on our overall view of the draft Environmental Impact Statement.

Today my comments will focus on the subject of transportation of spent nuclear fuel to the proposed EIS facility.

The draft EIS addresses transportation related to the CIS and includes radiological and non-radiological health and safety impacts under both normal and accident conditions.

And either could result from the proposed use of natural rail lines to transport shipments of spent fuel to and from the CIS facility.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Radiological impacts from transportation to workers in the public were found in this statement to be small and that was based on estimates from NRC's transportation risk work documented in NUREG 2125, Spent Fuel Transportation Risk Assessment.

The radiological impact to workers from incident tree transportation of spent nuclear fuel to and from the CIS facility for all phases were found to be below NRC's 10 C.F.R. Part 20 standard dose limit.

Let's take a look at that in practical terms.

Someone who stands about 100 feet from the tracks or present to observe all of the proposed 10,000 shipments over the 20-year period modeled in the proposal, that person would receive a total dose of about 6 millirem of direct radiation emitted from the heavily fielded transportation casks.

And that's less than what a person would typically receive on a round-trip cross-country airplane ride.

All of the spent nuclear fuel that's transported to and from the consolidated interim storage facility is going to be shipped in canisters that are placed in NRC-certified transportation casks.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 In the most recent analysis, again, in NUREG 2125, the NRC concluded that there would be no accidental release of canistered fuel during transportation under the most severe conditions.

These certified container designs must demonstrate that they can withstand a rigorous sequence of a drop, puncture, fire, and submersion task to confirm their ability to survive a simulated high-speed crash and a fire accident without releasing the contents.

Now, contrary to much of what has been said so far this afternoon, there is a very long and safe history of transportation of spent nuclear fuel.

Since the early 1970s, there have been at least 20,000 sink shipments of more than 80,000 metric tons of spent nuclear fuel worldwide, without any harmful release of radioactive material or personal injury.

Bringing it closer to home, there have been more than 1300 spent fuel shipments completed safely in the United States over the past 35 years, most of that being shipped by rail with no harmful radioactive release or environmental damage.

In fact, the United States Navy has completed nearly 850 shipments of spent fuel for

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 naval reactors, and there have been more than 250 transportation containers of spent nuclear fuel from foreign research reactors that have been to and within the United States over the past 30 years.

So, in conclusion, I'd like to reiterate that NEI supports the recommendations provided by the NRC and the Bureau of Land Management to issue an NRC license to Holtec to construct and operate a consolidated interim storage facility for spent nuclear fuel at the proposed location.

And that includes a permit to construct and operate the associated rails. Thank you very much for the opportunity to share these comments today.

MR. CAMERON: Thank you, Mark, thank you very much and we're going to go to Barbara Warren, if she's there, and then to Kelley Lundeen, and then I'm going to turn it over to Calvin to decide who comes on next.

Calvin, is there a Barbara Warren there?

MS. WARREN: Passcode? Okay.

MR. CAMERON: Is someone on?

OPERATOR: Ms. Warren, your line is open.

MS. WARREN: Hello, Can you hear me?

MR. CAMERON: Yes.

MS. WARREN: Oh, good, okay, thank you.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 My name is Barbara Warren, I'm a registered nurse with a master's in environmental health science.

And I represent Citizens Environmental Coalition in New York State. I'm going to jump around a little bit because there's obviously a lot to talk about.

I want to mention one thing I saw on your slides, that NRC found there would be no accidents in your analysis. And I'm assuming that's a result of basically simulated accidents, computer simulations, which I believe the previous speaker was also referring to.

It's simulations, that's very common in these types of analyses. Now, the U.S. Nuclear Waste Technical Review Board, which is an official advisory Board of experts, has called for full-scale testing of shipping containers.

That means in the real world actually testing. They recommend that a large locomotive approach from a 90-degree angle and attempt to damage the shipping container.

And that's what they feel will give the public more confidence in this inadequate modeling that is commonly done. So, I want to mention that as an important issue.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The other issue is that we have not passed a major infrastructure bill for more than a decade. That is, Congress and the presidents have talked about it but we're still waiting for it.

Repairs only could take more than a decade to do but we likely need many replacements for infrastructure, as pointed out by the American Society of Civil Engineers, who do a regular report.

Our last grade was D+ for our infrastructure.

So, this is a very serious matter, the state of our infrastructure in this nation, and to pretend that by doing a simulation, the limited testing that you do in a simulation is adequate is just absolutely faulty.

I want to mention that -- I just want to look for a minute at my notes here.

The Association for American Railroad study, done in I think it was 2007, they believe that the $135 billion would be needed nationally just to take care of the needs of the Class I railroads.

The Class I railroads are the ones that are needed to transport of these very, very heavy casks. New York State identified that to achieve good repair just within New York State they would need $730 million.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 That wasn't to do all the enhancement and other things they needed to do but just for good repair.

Unfortunately, because they had other priorities in New York State to deal with climate change for other infrastructure, they were only able to allocate $130 million for New York State, and that covered passenger and freight rail, not just Class 1 freight.

So, it gives you an idea that there is a lot of money that's needed to upgrade our infrastructure.

Now, the National Transportation Safety Board, which is a credible outfit, has identified two real priorities for the nation.

That's positive training control and the replacement of older tank cars that carry hazardous and flammable material.

We really don't want spent nuclear fuel traveling on the same routes as flammable or hazardous or liquid hazardous materials that could affect the spent nuclear fuel.

The Nuclear Waste Technical Review Board also in a recent report in 2019 identified the fact that there were 30 technical issues that need to be

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 resolved prior to transport of any high-level waste or spent nuclear fuel.

And the endeavor would take ten years to solve or to address all of these technical issues that they've identified. I want to also mention a much earlier report that's cited by the government frequently, that's the National Academy of Sciences report in 2006.

That report was completed in the absence of any information on security and terrorism.

That problem continues to this day despite the Nuclear Waste Technical Review Board identifying that in 2010, that security concerns had not been incorporated and they needed to be.

I want to also mention the high burn-up fuel. In 2010, that Board, the Nuclear Waste Technical Review Board said that high burn-up fuel was a serious, serious problem because we had no information about high burn-up fuel that was adequate.

All we had was testing of low burn-up fuel and that was totally inadequate because it's a different animal. High burn-up is basically very, very different.

And the shocks and vibration that occur during transportation could cause the embrittlement

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and damage to the fuel in transportation.

And that Board said that for a CIS facility, they would need a shielded hot cell for the arrival because there might be damaged fuel that would have to be handled in a shielded hot cell.

Or another name for it is a dry transfer system that the NRC identified in 2014 as being required in their final continued storage rule. They said it had to be implemented at every IFSI, every independent fuel storage installation would have to have these dry transfer systems.

And you're ignoring your final rule when you're talking about these CIS facilities and not planning for any of these shielded transfer systems.

So, there's a lot of questions about how you evaluated the safety of the current CIS that you're evaluating when you're ignoring all these recommendations of official bodies.

MR. CAMERON: Thank you.

MS. WARREN: Thank you very much.

MR. CAMERON: Calvin, are you still with us?

OPERATOR: Yes, sir.

MR. CAMERON: Okay, can you see if Kelly Lundeen is on? And then, Calvin, as I mentioned to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you before we're going to go to you to establish what the queue of speakers is.

And you can just put on the people in order you get them, but let's see if Kelly Lundeen is there?

OPERATOR: Ms. Lundeen, your line is now open.

MS. LUNDEEN: Hello, Can you hear me?

MR. CAMERON: Yes.

MS. LUNDEEN: My name is Kelly Lundeen.

I'm affiliated with Nukewatch, an organization in Wisconsin.

I live here in Wisconsin, a state known for its beautiful blue lakes and bordered by the Great Lakes, the largest fresh water bodies in the world.

Lake Michigan is under severe threat by Holtec's thirst for profit and the nuclear power industry's desire to rid itself of the liability of the high-level radioactive waste referred to in the BISS spent nuclear fuel that it has created and profited from in order to shift the financial risks of inevitable accidents from itself to taxpayers.

The only reason for a centralized interim storage facility to exist is to bring radioactive waste from other places. The only way for Holtec to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 fulfil its purpose for the proposed facility is for a massive cross-country shipment to occur.

Section 3.3.2 of the BIS, entitled Transportation for Nuclear Power-plants into a Permanent Repository, it says if the proposed DISF is loaded to full capacity then it is reasonable to assume that shipments of SNF, spent nuclear fuel, would come from most or all existing reactor sites nationwide.

Additionally, the SNF stored at the proposed CISF project would eventually need to be transported to an offsite geological repository.

It continues, the NRC Staff consider the relative evaluated in these prior transportation analyses, which is referring to the Yucca Mountain EIS, to be representative or bounding for SNF shipments to and from the proposed BISS project because they were derived based on typical transportation industry selection practices.

They considered existing power-plant locations and they covered large distances across the United States with adverse transportation characteristics, end quote.

Yet the scope of the risks to the public and workers from an accident during transportation

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 from those 129 reactors in New Mexico is not adequately addressed, except to describe it as, quote, unlikely in the DDIF.

And therefore, a violation of the 1970 National Environmental Policy Act, as ruled by federal court.

I think we should be given more time in order to read off the titles of these sections.

This is Section 4.3.1.2.2.3, radiological impacts to workers and the public from SNF transportation accidents says all of the estimated radiological health effects to the public from the proposed SNF transportation under accident conditions are below aforementioned ICRP threshold and are therefore likely to be --

(Simultaneous Speaking.)

All of the estimated radiological health effects to the public from the proposed SNF transportation are likely to be zero under accident conditions.

That's BS, yet the table 4.1-3 is called comparison of estimated population doses and health effects from proposed transportation of SNF to the proposed CISF along a representative route with non-project baseline cancer admits that health effects

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 include fatal cancer, non-fatal cancer, and severe hereditary effects.

If questionably low, estimated health effects in the EIS are true, they are still not acceptable risks. The electricity produced at nuclear reactor sites was consumed by those of us living here, which for me is Wisconsin.

We have no business shipping this waste off to pristine land and central land of indigenous people who have not been adequately consulted, and where the local community, which is primarily Hispanic, does not welcome it.

It is an environmental injustice to send what could be the largest quantity of radioactive waste to any one place in the world and dump it on the land of a community that has made it loud and clear in their 18 resolutions that they do not consent.

There's no safe level of exposure to radiation yet the deadly risks involved in the transportation of this dangerous material are barely mentioned in the BIS, which make it null and void.

Of the 129 reactor sites where radioactive waste is currently stored from which the waste would come to be placed in New Mexico, few of

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the sites are even mentioned in the EIS and no maps are provided.

In order for Holtec to operate this facility, radioactive waste casks would have to be shipped throughout the country by train, truck, and barge.

En route it would travel within a couple miles of the homes of 100 million people in the United States, not to mention millions more who would be exposed as they share public roads where casks would travel past at speed limit.

To remove the radioactive waste from my state, there would be up to 453 barges carrying radioactive waste on our precious Lake Michigan, a place that's revered and respected internationally, a place where I have swam, camped, gone to play with bikes, held birthday parties, and gone to Summerfest.

If this lake is contaminated, if a barge full of radioactive waste larger than Chernobyl, what will Lake Michigan be known for?

The EIS is really flawed and inadequate

-- I'm finishing -- since it doesn't address the scope of the risks of transportation of the radioactive waste required for operation of the facility.

I support no action alternative and continue in person meetings. Thank you.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Thank you, Kelly, for identifying individual sections for your comments.

Now, Calvin, are you there?

OPERATOR: Yes.

MR. CAMERON: We're going to go to you controlling who's in line to speak. So, will you take it from there and tell us who's going to come on? And we'll just keep going here.

OPERATOR: Thank you. So, at this time, we're going to continue taking comments. I will need you to press Star-one on your telephone key pad to be entered into the comment queue.

That is Star-one to be entered into the comment queue. Comments will be taken in the order they are received.

One moment please.

Okay, our first comment comes from Brooke Holland. Your line is open.

MS. HOLLAND: Yes, hello, can you hear me?

MR. CAMERON: Yes.

MS. HOLLAND: I am Brooke Holland and I am from the Nuclear Issues Studies Group, and I want to comment that we do not consent to Holtec.

The draft Environmental Impact Statement

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 is not only a complicated mess but severely understates and misconstrues the true impact Holtec will have on southeast New Mexico, the rest of the state, and the country.

While there are many major reasons why this draft Environmental Impact Statement is lacking, many of which have been and will be mentioned tonight by those who see the obvious environmental danger of the project.

I want to focus on the lack of the draft statement's focus on the environmental racism that Holtec's project will perpetuate. And I want to say that it's appalling, that lack of focus is appalling.

Not only have the communities most impacted not been truly listened to in this decision process, but the cumulative impacts from the historical presence of the nuclear industry in the State of New Mexico has not been considered.

And if they were the so-called small, our no-impact ratings would not have been given for the potential environmental racism, as others on this call have commented on.

At a time where the reality of the racial inequality and environmental racism at the forefront of the nation's consciousness, it is grossly

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 irresponsible for the NRC and/or Holtec International to refuse to acknowledge their complicity and even active participation in enacting environmental racism in the form of nuclear colonialism that started over 75 years ago.

Especially in the face of the 75th anniversary of the Trinity testing in South Central New Mexico.

It is absolutely necessary for the finalized Environmental Impact Statement to explore in much greater detail how Holtec's centralized interim storage facility would perpetuate environmental racism.

As it stands right now, it is severely lacking.

As a final note, I'd like to echo other people's calls for this licensing period and public commenting period to be suspended or extended until safe in-person meetings can be held around the state.

Thank you.

MR. CAMERON: Thank you, thank you very much, Brooke. We're ready for the next speaker, Calvin.

OPERATOR: Yes, it comes from Eileen Shaughnessy, your line is open.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MS. SHAUGHNESSY: Can you hear me?

MR. CAMERON: Go ahead, Eileen, we're here.

MS. SHAUGHNESSY: My name is Eileen O'Shaughnessy and I'm with the Nuclear Issues Studies Group, a grassroots volunteer group based in Albuquerque, New Mexico.

My comments today are going to be focused on two things which lie at the heart of this proposal and this licensing process: racism and arrogance.

This proposed project is illegal, it's dangerous, and it's arrogant.

It is arrogant and flawed to assume that it is possible to do something that has never been done before: transport the most dangerous and radioactive waste we humans have ever created across hundreds of thousands of miles without accident or incident over 40-plus years.

I have absolutely no faith in this supposedly neutral and objective body, the Nuclear Regulatory Commission, or NRC, to do what they are tasked with doing, protecting the public and the environment.

Why? Because they have written a draft Environmental Impact Statement that leads us to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 believe that there are small to no impacts for this project.

And they are clearly covering their ears to the cacophony of voices that are calling for this project to be stopped.

The NRC is a puppet of the nuclear industry and to my knowledge, it has never denied a license proposal, and that's what we're seeing play out here today. This project is racist.

We are witnessing an unprecedented uprising and global pandemic. It is revealing the virus that are racism, which is alive and well in America.

The virus of racism is at the center of this proposed project, no matter what EIS says. The NRC has failed to translate the full DEIS into Spanish, the language spoken by a large percentage of communities who would be most impacted.

I want to be clear about what is on the table here. Holtec, a private company, is asking Federal Government, not the State of New Mexico, to transport forever deadly waste across the United States and dump it on a poor state with a majority of people of color.

How dare you not identify that as

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 environmental racism? This is environmental racism and it's an extension of colonialism. Now is the time to take leadership from indigenous people.

We have heard from multiple indigenous people on this call their opposition.

In addition, multiple resolutions have been passed opposing the transportation of high-level nuclear waste by the All Pueblo Council of Governors, which represents 20 sovereign pueblo nations, the Church Rock Chapter of the Navajo Nation, and the Navajo Nation Dine Uranium Remediation Advisory Commission.

Holtec may not be asking the State of New Mexico or the many sovereign indigenous nations to commission, but our core of voices is answering loud and clear.

We don't want your racism and we don't want your arrogance. New Mexico is not a wasteland.

MR. CAMERON: Thank you for those comments, Eileen. And we're ready for the next person, Calvin.

OPERATOR:

Next we have Karen Shaughnessy. Your line is open. Karen, your line is open? I'll move to the next comment.

That's from Jasmine Harvey, your line is

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 open.

MR. CAMERON: Jasmine, are you there?

MS. HARVEY: Hello?

MR. CAMERON: Is that Jasmine?

MS. HARVEY: Hi, this is Jasmine Harvey.

My full name is Jasmine Harvey, I grew up in Las Cruses, New Mexico, and my family lived in Las Cruses.

I currently live in Albuquerque, New Mexico.

My family and I are bilingual and my mother's first language is Spanish.

I am extremely concerned that the NRC has failed to completely translate, and I note completely translate, the draft Environmental Impact Statement into Spanish because in southeastern New Mexico, where this waste would potentially be stored, many of those impacted by this are Spanish-speaking.

I see this as a blatant form of racism.

I oppose this project and call on the NRC to fully translate every document into Spanish, Dine', and every language spoken by impacted communities.

(Non-English language spoken.)

MR. CAMERON: Thank you, thank you very much, and Calvin, could you put the next person on, please?

OPERATOR: Yes, our next comment comes

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 from Gary Hedrick.

MR. HEDRICK: Hey, I'm on.

MR. CAMERON: Is this Gary? Gary, go ahead.

MR. HEDRICK: Gary Hedrick with San Clemente Green, and we're in Southern California.

I'm only seven miles away from the San Onofre nuclear power-plant and I represent about 5000 concerned citizens in our vicinity that often get misrepresented.

So, I wanted to take this opportunity to clarify any misunderstandings that are often put out there by proponents of moving nuclear waste to New Mexico.

Because it's easy to believe that someone with that much waste 100 feet from the ocean buried at the water level would be anxious to move nuclear waste from that site to take it anywhere, and that is so far from the truth.

And I want to be sure the people on this call and people around cities and on transportation routes understand that we, the people that are next to this waste problem right now, are not so anxious to move quickly.

In fact, we believe we are decades away

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 from having the need for any kind of impact report like you're doing today, because our research shows that these canisters are not suitable for transportation.

And they won't be until we can actually do what is required, which is have the capability of reloading or repairing one of these thin canisters into a more suitable storage system.

And that requires an on-site hot cell or a facility that can accomplish that task. And we are so far away from that, I think we should put everyone's minds at ease that we, the people close to the problem, are not sending our problem to you, and especially the indigenous people.

And the many concerns that we have have recently been confirmed in a report that I was involved in with representative Mike Levin, who did a Congressional taskforce.

And that taskforce was chaired by the former head of the NRC, Gregory Jaczko, and retired admiral Len Herring, who did an excellent job working with Mike Levin to come up with very conclusive and revealing facts that need to be resolved and questions that are not resolved.

A report recently came out and I highly

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 recommend everyone look into that report because it's a very scathing report on the NRC, for a big portion of it.

And it also stressing the need for further research and developed of new ideas, solutions that have yet to be resolved.

And just to put it clearly in plain English, the most likely scenario for the next 200 to 300 years, based on what I've seen and what's been discussed, is a solution similar to what Switzerland has done with the Zwilag Facility, where they've taken nuclear waste, put it in thick casks, instead of thin canisters, and stored them in robust buildings which have a capability of protection from terrorist attacks and natural disasters.

And there's robotic systems in place that ensure that we won't have the kind of accidents like we almost had when Holtec had 5010 canister hanging, suspended by a quarter inch, nearly dropping 18 feet to the bottom of the silo.

So, we're only dealing with 73 canisters here. And thank God we haven't had another near incident, we're almost through that phase, but I think it's imperative to understand that you're talking about 10,000 canisters.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Something is going to go wrong and we're not ready to deal with it, with the facilities to deal with damaged canisters. So, I'd like to put people's mind at ease that we are not pushing this problem on anyone.

We think the nuclear waste is going to remain near this site, and hopefully in a facility like the Switzerland solution.

And just for a point I'd like to make about their solution, they only figured a 40-year period before there would be a permanent repository.

And yet they went through that huge investment, which is phenomenal in terms of technical advancement.

So, if they can do it, we can do it and we're not going to listen to the NRC, who is a captured regulator.

We're not going to listen to Edison or the industry spokespeople that like to create community engagement panels that misrepresent the public sentiment.

We're going to move forward with our brothers and sisters across the country and make sure this is done in the best way for the greatest good of all.

And I just want to make sure that's

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 clearly understood and backed up by science and task reports that validate our feelings. So, no need to do this Environmental Impact Statement.

It's decades premature and we're going to work on real solutions right here.

Thank you.

MR.

CAMERON:

Thanks for that clarification, Gary. Who's next, Calvin?

OPERATOR: Next we have Karen Hadden, your line is open.

MS. HADDEN: Hi, I'd like to say, first of all, I represent the SEED Coalition. We work statewide in Texas and we have worked in coordination with many people in New Mexico as well.

We're very concerned that the southwest region of the country is being targeted and this is environmental racism of the highest magnitude. I can't think of a more egregious example of what could be done.

To take the most dangerous waste in the whole world and to gather it from around the whole country and dump it on the region of the country that is largely Hispanic, indigenous people, people of color, that is immoral.

That is environmental racism, it should

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 be clear in the DEIS that's the case.

If you want an example, here's one, the rail line to El Paso to Monahans within five miles of either side, according to the EPA's EJ screen, is what they call 94 percent Hispanic. Many of those people do not speak English.

That is one area where the waste would be transported. How many of those people know about this?

How many of the people in the low-income community next to the rail lines in El Paso, where trains could sit for days, irradiating the community, how many of them know?

This is absolutely wrong. It's illegal.

This hearing should never be happening. And furthermore, I'm incredibly disappointed in this public meeting itself because we can't see the faces of any of you.

Now, I've hosted webinars and I've had 30, 40 people on there and we managed to make that technology work. Why can the Nuclear Regulatory Commission not manage that?

Why are we sitting here calling on people and not able to reach them? This is incredible amounts of time wasted and this system of switching all of the sudden to first come first serve, where

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 did that come from and why?

I signed up ahead of time and I didn't make it on that list. I question how this is being done, I question the fairness of it, the notice of it. I think we've got some real serious problems and need to go back and do over what is happening here.

I take issue with the statement that the Nuclear Regulatory Commission is not promoting these projects, because everything I have seen is to the contrary.

We've got judges who have tossed out health and safety

concerns, 100 different contentions. They included not having a dry task transfer facility at the site. Why are these things disregarded as a safety issue?

That is just incomprehensible that could be considered. And Gregory Jaczko was mentioned earlier, former NRC Commissioner.

He has said that anybody who thinks that CIS is temporary is wrong, that the waste would get there and never move again. It will be in a facility that is not a permanent repository.

It will not be safe for the long-term but we won't be able to move these damaged, leaking casks and canisters. We have to prevent this. It's a

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 nightmare.

It's an illegal, immoral nightmare and this meeting should not be being held. This DEIS is inadequate in every way. Anyone could sit down at a computer and compile a set of facts that are put in there and called a DEIS.

But what's lacking is analysis, what it means, how do these things relate? What are cumulative impacts? How do they actually relate?

Nobody mentioned that the website had an accident that had $2 billion worth of damage. That should be included in discussion of environmental impacts and cumulative impacts. Why is that eliminated?

This is a farce. The document is just plain wrong. It's factually inadequate, it's pseudoscience.

And when you get done reading a document like this, you'd think that we're not talking about the most dangerous substance on earth. You would think we were talking about children's stuffed toys or something.

Because, really, how can you come out with small as an amount of risk? It just doesn't make sense. There's a couple reasons why.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The transport, largely by train, would involve rail cars and loaded up casks and canisters that weigh up to 210 tons. But the rail tracks that they would travel on in many areas are rated for only 143 tons per rail car.

That is an accident waiting to happen.

Studies that were done for the State of Nevada, when we were looking at shipping this same waste to Yucca Mountain, found that this was the DOE.

They said train accidents were anticipated at a rate of 1 in 10,000 shipments, and at least one train accident was expected to occur if transport was mainly by train.

They were looking at 70,000 tons and this is roughly 2.5 times that for the Holtec site.

MR. CAMERON: Karen --

MR. CAMERON: Karen, I --

MS. HADDEN: So, how can we say --

MR. CAMERON: -- apologize, I'm going to have to ask you to --

(Simultaneous speaking.)

MR. CAMERON: I'm going to have to ask you to finish up, Karen.

MS. HADDEN: I will finish up briefly.

The DOE also has reported that a severe accident that

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 released only a small amount of waste would contaminate a 42-square-mile area, clean up costs exceeding $620 million in a rural area. In a downtown area, it could cost $9.5 billion to raze and rebuild the mostly heavily contaminated square mile.

So, these things should be in the draft Environmental Impact Statement, which is woefully inadequate. It equates to a lie, it's pseudoscience and it needs to be done over.

And public meetings need to be held that are real, in-person, where we can see the faces of the people who are promoting this project of dumping on --

MR. CAMERON: Okay.

MS. HADDEN: -- people in the Southwestern United States.

MR. CAMERON: Thank you. Thank you, Karen. And, Calvin, put the next speaker on, please.

OPERATOR: Yes. Our next speaker comes from Noreen Shaughnessy. Your line is open. Your line's open.

MS. SHAUGHNESSY: Hello. Hello, hi. I am Noreen Shaughnessy. I live in St. Paul, Minnesota, which is a state that has several nuclear reactors. And we do not, I repeat not, want to send

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the waste across, all the way across the country to New Mexico.

It's no coincidence that the United States wants to make New Mexico a nuclear wasteland.

It ranks as one of the poorest states and is a majority minority state, with more Black, Indigenous, People of Color residents than White residents.

For the NRC to determine that nuclear waste, which will threaten life for millions of years, would have, quote, small or, quote, no environmental impact is a blatant violation of environmental justice principles and is environmental racism in action.

We absolutely do not give our government, our own government, license to allow a private, repeat private, industry to further contaminate our home and to expand the massive nuclear burden we already bear in New Mexico and elsewhere, and by hauling this waste across the country.

If there's a definition of insanity, this is it. Please listen and open your hearts and minds and ears to the truth. Thank you for listening and please.

MR. CAMERON: Thank you.

MS. SHAUGHNESSY: -- please receive --

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Thank you for your comments, Noreen. We're ready, Calvin.

OPERATOR: Our next comment comes from Matteo Peixinho. Your line is open.

MR. PEIXINHO: Yes, hello. I appreciate the opportunity to address you. I would defer to our Native leaders that have already spoken, but I think it's important for me to add my voice.

I think this whole proposal and this whole process is a farce. The idea that you're going to come and put all this waste here temporarily, for hundred years or so, is ridiculous.

I was part of the movement in Nevada that convinced the state leaders and communities to oppose Yucca Mountain. And once the people became aware of what the NRC was proposing for that sacred space, the Shoshone land, they rose up against it.

And even though you had wasted billions of dollars building the facility, calling it a test pilot tunnels, you actually constructed the place, the community rose up, the state rose up, and got the project stopped.

If you do bring this waste, I live in New Mexico, just up north, if you do bring this waste here, you'll never pick it up again, and you should

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 be ashamed of yourselves for even proposing this concept that is absolute nonsense. And I don't know how you go to sleep at night.

I work every day in construction and I see what happens in the field, we make mistakes, we get hurt, accidents happen. And what you're proposing will be contaminating the entire routes that you plan to use and it will be a disaster for this area of New Mexico.

So, I'm begging you, I would give my life to stop something like this from happening, and I just wish you would all reconsider your way you make a living and try to do something good for the Earth, good for the people.

The fact that we as New Mexicans have to spend our time now rallying up and educating ourselves and one another about this absurd proposal, wasting our time, rather than being able to focus on the real disasters we have at hand.

I live a few miles from Los Alamos National Labs. Many community members here have had to resort to accepting their payoffs of their death of their loved ones. You need to stop this immediately, turn around, you're on the wrong track.

Thank you very much.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Thank you. Thank you very much, Matteo.

OPERATOR: Next, we have David McCoy.

Your line is open.

MR. MCCOY: Hello, this is Dave McCoy.

I'm a director for Citizen Action New Mexico. In or about 1975, I was an intervener on the Trojan Nuclear Power Plant's expansion of spent fuel, docket number 50-344.

They told me at that time that I couldn't discuss where the waste was going to go, because the government assured us that within five years, Yucca Mountain was going to open. There's still spent fuel sitting 100 yards from the Columbia River.

Now, I want to focus for a minute on the out of scope issues, because this is how the NRC constructs its DEIS, I call it the three monkey approach, hear, see, speak no evil.

So, out of scope comments are the NRC licensing framework, decommissioning, financial assurances, business practices of involved parties, like Holtec, it likes to bribe people and make false applications to the state for funding, political decisions, like the State of New Mexico is telling you they don't want it here, opposition to nuclear

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 power, weapons, and industry, and calls for renewable energy sources.

Out of scope is legacy

issues, segmentation of the spent nuclear fuel, Nuclear Regulatory Commission credibility, comments regarding Yucca Mountain, use of Yucca Mountain as a repository or lack of available repository, cask and canister fabrication quality, transportation of high burnup spent nuclear fuel, security, and terrorism.

Out of scope comments in your Safety Evaluation Report.

Now, look, you know that this can be here in this state for up to 120 years. This makes the 40-year analysis of the DEIS a pile of poo-poo. You have not analyzed the environmental impact for 120 years. So, then, you have these nuclear reactors that you're granting 40-year license extensions to, to keep producing this spent fuel.

Now, where's all that spent fuel going to go that's all being produced anew? Are you going to ask for an expansion of the Holtec site in New Mexico?

Along with this is the stupidity of spending billions and billions of dollars to move all this stuff to New Mexico and then, how much is it going to cost and where are you going to send it after New Mexico?

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 You don't have a clue. That's why you make a comment about the lack of a repository an out of scope comment. Now, look, we're not stupid people here in New Mexico, even though our school system is not up to snuff. But you can't make this crap fly, it just doesn't work.

Take, for example, 2.3.6, regarding criticality, the efficacy of neutron absorbing materials will last 20 years, according to that.

Twenty years. That's not 40 years, that's not 120 years.

6.0 in the SER, an amendment was necessary for the cask system. They didn't want to make the transition to an 80-type assembly, they won't fit. So, then, Holtec withdraws the proposal to have the system.

You didn't do any high burnup analysis.

That's clearly within the -- one of the problems that everybody has mentioned about transporting this fuel and storing it and removing it down the road.

So, you people are just full of misrepresentations, lies, illegal documentation.

I've been doing this kind of stuff since 1975, at the Trojan nuclear reactor.

I come to New Mexico, you've got the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 mixed-waste landfill. I told the Nuclear Regulatory Commission, you've got spent fuel in that site and you won't do anything about removal of that, you won't pay any attention at all to that.

Now, the State of New Mexico has had a proposal under the five-year report from Sandia Labs that they can move that stuff out of there. But the State, apparently, is so underfunded that it can't even respond to removing a local 2.6 acre dump.

How are you going to remove all of the nuclear fuel after 120 years, or even 40 years, from New Mexico, and where are you going to put it? That's the elephant in the room. And if you don't answer that question, everything that you're telling the public in this DEIS is just a load of poo-poo. That's the only way to put it. Thank you.

MR. CAMERON: Okay, thank you. Thank you, Dave. Who's next, Calvin?

OPERATOR: Our next comment comes from Brendan Shaughnessy. Your line is open.

MR. SHAUGHNESSY: Hello?

MR. CAMERON: Hello, Brendan.

MR. SHAUGHNESSY: Can you hear me?

MR. CAMERON: Yes.

MR. SHAUGHNESSY: All right, thank you,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Chip, and I appreciate your work today, Calvin.

First, I'd like to thank all the commenters before me, especially those who are Indigenous, non-male identifying, or nonbinary.

And

again, my name is Brendan Shaughnessy. I'm a part of the Nuclear Issues Study Group in Albuquerque, New Mexico, USA, Planet Earth.

And this is an issue that affects us all. And that's the first point I'd like to make today, during the comment period.

I'd like to echo Senator Steinborn's comments from the last phone call that this issue impacts everyone. And for those commenters that have stated, in Carlsbad especially, that it's only important for them to have their voices entered, that is absolutely incorrect, because there are many, many people all along the transport routes throughout the country that will be impacted.

And Holtec is not from New Mexico and they're not welcome. The people have spoken, this is not a project that we are condoning. And, furthermore, we, as I just stated, do not consent.

The motto of the Nuclear Regulatory Commission is protecting people and the environment, yet the NRC's draft Environmental Impact Statement on

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the Holtec project does neither. Instead, the NRC's inadequate draft EIS puts people, wildlife, and precious water resources at significant and potentially deadly risk by failing to heed the concerns of the community.

We join the All Pueblo Council of Governors, New Mexico Governor Michelle Lujan Grisham, New Mexico State Land Commissioner Stephanie Garcia Richard, more than a dozen county and city governments, the Alliance for Environmental Strategies, the New Mexico Cattle Growers Association, the Permian Basin Coalition of Land and Royalty Owners and Operators, the Nuclear Issues Study Group, and the more than 30,000 residents who commented during the 2018 scoping period in vehemently opposing bring the nation's high level radioactive nuclear waste from nuclear power plants to our communities. We do not consent to becoming a nuclear waste land for millions of years.

Furthermore, cumulative impacts, the DEIS is inadequate because it fails to consider cumulative impacts from the damage that the nuclear industry has already inflicted on New Mexicans for the past 75 years.

Uranium mining and milling in the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 northwest on Indigenous Dine and Pueblo land, including the 1979 Church Rock disaster, radioactive contamination to Tewa lands and people from the Manhattan Project in the Los Alamos area, fallout on downwinders from the Trinity testing in the Tularosa Basin, the waste isolation pilot plant, which has already accidentally released dangerous amounts of radiation and now wants to expand, the Urenco uranium enrichment plant in Eunice, the world's largest nuclear warhead stockpile on the edge of Albuquerque, and the toxic threat to Albuquerque's aquifer by the mixed-waste landfill.

Rather than adding 173,600 metric tons of high level radioactive nuclear waste to a state that has already been grossly overburdened, the United States should be directing its resources towards cleaning up the contamination already present in our communities, just compensation, and holistic community health studies.

The DEIS also fails to account for cumulative impacts from the other proposal for Consolidated Interim Storage, approximately 40 miles east, at the current waste control specialist's low level radioactive waste site.

It's no coincidence that the United

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 States wants to make New Mexico a nuclear wasteland.

It ranks as one of the poorest states and it's a majority minority state, with more Black, Indigenous, People of Color residents than White residents.

For the NRC to determine that nuclear waste which will threaten life for millions of years would have small or no environmental impact is a blatant violation of environmental justice principles and is environmental racism in action.

We do not give our own government license to allow a private industry to further contaminate our home or to expand the massive nuclear burden we already bear.

Holtec International and the NRC would have us believe that the site is a desolate, uninhabited place with no historic value or significance. This statement is completely false and without merit.

The site is located near or on two lagunas or playa lakes, Laguna Gatuna and Laguna Plata. Laguna Plata is an archeological district that has been extensively studied for decades. Two sites near Laguna Gatuna, where the nuclear waste is proposed to be stored, are listed on the National Register of Historic Places.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Archeologists have found a plethora of evidence on the Jornada Mogollon people dating from 200 AD to 700 AD and 1200 AD. More than 200 archeological sites are located within six miles of the proposed nuclear waste dump.

Laguna Gatuna, while often dry, fills with water after monsoon rains, attracting a variety of wildlife and hunters for millennia.

The Hopi and Mescalero Apache Nations have identified the area as culturally significant to them, and the Hopi Nation has informed the NRC that traditional cultural properties could be adversely affected if this project proceeds. The site where Holtec --

MR. CAMERON: Mr. Shaughnessy --

MR. SHAUGHNESSY: -- wants to dump tens of thousands of tons of radioactive waste --

MR. CAMERON: -- I'm going to have to ask MR. SHAUGHNESSY: -- has profound --

MR. CAMERON: -- you to stop.

MR. SHAUGHNESSY: -- historic -- oh, is that Chip?

MR. CAMERON: Yes, thank you, very good, thank you for those comments. We're going to move

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on to the next speaker, we still have several --

MR. SHAUGHNESSY: Thank you for --

MR. CAMERON: -- people to go. But thank you, thank you very much. Calvin, who's next?

OPERATOR: Next comment comes from Kayleen Walker. Your line is open.

MS. WALKER: Hello, can you hear me?

MR. CAMERON: Yes. Hi, Katie.

MS. WALKER: Great. Kayleen.

MR. CAMERON: Kayleen.

MS. WALKER: Okay. There's a few things.

I notice you make an assumption that there would be no radiation release in an accident.

It reminds me of the ASLB hearing, where Holtec was asked if they planned to have a hot cell at the facility and the answer was no, there wouldn't be any need for it, these canisters won't need to be replaced or repaired or anything. So, I thought that was interesting that the ASLB, the Board, allowed that to go through.

They also asked Holtec what would happen if a canister was leaking when it arrived and Holtec confirmed that the policy would be to return it to sender. So, the assumption that these canisters, that there will be no problem with these canisters,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I believe is a false assumption. I don't know whose scope that is within, it might be out of scope of this particular hearing, but I thought I'd bring that up.

The DOE published a draft analysis report in December 2019. They changed their gap analysis.

The gap analysis is a gap in their understanding or their knowledge.

So, they changed their analysis of cladding failure from a Priority 7 in 2012 to a Priority 3 in 2019. And this is the hydride reorientation, embrittlement, and those effects.

So, that was changed to a higher priority.

They changed the consequences assessment of canister failure from nothing they were looking at to a Priority 3. They changed the priority of canister corrosion issues to a Priority 1.

So, I'm a local of the San Onofre, the NRC knows us as SONGS. And the site evaluation that was approved by the NRC is 100 feet from the ocean, a couple of feet above ocean sea-level.

That site was approved with absolutely no consideration for being able to move the fuel, no consideration for a destination of where it might go, no consideration of the financial

cost, no

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 consideration of the legal ramifications. We, in this area, do not want this to go to New Mexico.

The canister system that the NRC has approved is absolutely unacceptable. If you'd like to look at the experimental nature of the Holtec canister system, go to the NRC home page, go to the spotlight section, go to the cask loading issues web page, and you'll see a whole list of the saga of what we've endured here as the experimental system has been, we've been doing troubleshooting to try and be able to even just download the canisters safely.

Which they can't, they get scraped and gouged. Stainless steel against a carbon steel guide ring, introducing new corrosion considerations. The NRC has ignored that and basically bent over backwards to accommodate the industry.

If the NRC would simply enforce Title 10 Part 72 for storage, Part 73 for transportation, we wouldn't be in the mess we're in, where we have 3200 welded thin wall canisters loaded across the country with no long-term safety considerations. There's no way to retrieve the fuel, which is a requirement in Part 72.

The ISGs that the NRC has continually created, there's many, ISG-2, for people listening on

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 this call, I'm mostly speaking to you, ISG-2 Revision 2 redefines the definition of retrievability.

So, instead of having this stuff stored in canisters that you can retrieve the fuel if there's a problem, they've welded them shut, they've allowed these things to be welded shut, and you don't -- they eliminated that requirement to have the fuel be retrievable. That's a requirement of the NRC Title 10, but ISG makes it a loophole.

So, this fuel is welded shut, there is no facility across the country able to repackage this fuel. We're being booby-trapped by the canister system that Holtec and others put out and that the NRC approves.

People like the NEI, who was on earlier, they are actively promoting industry interests and the NRC is accommodating them. This is an extremely serious, egregious failure to protect public safety.

And I'm not sure how we're going to get to the bottom of it, but these Chernobyl cans should not go anywhere, they're all going to need to be repackaged. So, I suggest the NRC consider designing and building hot cells and troubleshooting that process of repackaging this fuel.

I've spent four years of my life studying

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 this after I learned that the Holtec ISFSI concrete slab had already been built, I got wind of what was going on. And I've --

MR. CAMERON: Thank you.

MS. WALKER: -- looked into NUREGs, read these documents. I didn't have time to get into the CIS, but what's happening is --

MR. CAMERON: Kayleen, I'm going to have to ask you to stop now, you've given the staff here a lot of information and things to think about and I thank you.

MS. WALKER: Well, I hope the public understands and we need to communicate amongst ourselves because the NRC usually uses our information against us. Thank you.

MR. CAMERON: Thank you. We're ready for the next speaker, Calvin.

OPERATOR: Our next speaker is Christopher Carson. Your line is open.

MR. CARSON: Yes, hello, Christopher Carson here. I'm from Fort Worth, Texas, I'm a private citizen representing nobody but myself. And the thing is, I keep hearing people calling for the opinions of the impacted populations living along the transportation routes.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Well, I am it. I live here in Fort Worth, Texas, which is one of the nation's major rail hubs. We also have, of course, nearby the Comanche Peak Nuclear Generating Station, but that's not really important in this case.

What's important here is that major rail lines run through and intersect in Fort Worth, we have major rail yards here. And I can tell you from my own personal experience, just driving around and being stopped at grade crossings, that hundreds and hundreds of carloads every day move through this city of, for example, liquefied petroleum gas and chlorine.

These are incredibly dangerous substances, because they're corrosive, they're toxic, they can leak and explode, they're volatile, they're under high pressure, and they're contained within a fairly thin steel shell.

And it's a real testament to the railroad, entire railroading profession that despite this, frankly, astonishingly dangerous cargo, which would raise the hair of most of the kinds of people who've been calling in, I'm sure, as well as most people just generally around the country, we have not had, very, very few and far between are any kind of

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 instance which posed the least hazard to human life, to public safety, or even to property, which I definitely put at the bottom of the chain there.

And I'm always sort of amazed and gratified by the professionalism of the railroaders of this country for that reason.

But that's -- and so, what we have to think about here is that during the Windscale Inquiry, back 40 years ago now, one of the most eminent jurists in Great Britain found, on the basis of the evidence that was presented to him, that the transport of spent nuclear fuel was considerably less hazardous to the public than the transport of chlorine, which I mentioned I see chlorine tankers go by not far from me every day, if I care to look.

So, how has that judgment changed in the last 40 years? So, the answer is it hasn't changed at all, unless to strengthen it, because we have had another two generations, when that statement was made, there was only about 20 years' worth of experience, but today, right, we've got an additional 40 years' worth of experience of shipping spent nuclear fuel in the United States and around the world.

And not once, not once has one of those

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 transport flasks cracked open. And even if it did crack open, we have to ask what would happen if it did?

The contents aren't liquid, they're not gas, they're not under pressure, they're not even a powder, there's no reason for them to try to escape.

What you have in there is a solid refractory ceramic substance, which it has to be by the nature of the job it does, which is wrapped up in layer after layer after layer of metal.

Now, we've had full-scale tests of nuclear flasks under all kinds of accident conditions, here in this country and elsewhere.

We've had locomotives rammed into trucks carrying nuclear flasks. We've had nuclear flasks dropped from helicopters, we've had them dropped into pools of burning jet fuel, we've had all those test done.

And it's amazing, the various flasks that have constructed around the world, to the same common set of international standards, do seem to do the job they were expected to do, which again is a testament to the engineering profession, which seems to know what it's doing. Which I always find very gratifying, my own education is in the engineering field.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And so, personally, I get very worried, because I hear the people who object to this proposal talking about Chernobyl, they call these canisters mobile Chernobyls, they talk about Chernobyl on Lake Michigan, Chernobyl cans, you keep hearing the word Chernobyl mentioned over and over.

And, of
course, any rational investigation of this would show that there's absolutely no danger of what happened at Chernobyl, because what happened at Chernobyl was a power excursion, which literally dispersed the entire contents of a reactor, divided it up into little fine chunks, and spread them all over the landscape.

Even at

that, the consequences of Chernobyl are less than we would have expected for an accident like that. But that's not the point here.

The point is that Chernobyl comparisons are completely irrelevant.

The only reason I can see why these people are making these comparisons is to generate an emotional response, because they don't have facts to stand on. They are trying to mislead and deceive the public by sensationalism.

I don't believe that people like that have the right to make national policy and I am

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 totally indifferent to this project, but I am going to support it purely because the people who object to it are making bad arguments, they're bringing in falsehoods, and they have absolutely not a leg to stand on with the things that they say.

I am deeply offended by the idea that our national policy should be carried on on the basis of what people want to claim about scientific facts and engineering, rather than the actual experience and the actual data which shows something completely different than what they

claim, that their sensationalism should not be making our national policy.

And, therefore, I am forced, as a matter of conscience, to speak out in favor of this Consolidated Interim Storage Facility, even though I regard it as by far not the most appropriate way of dealing with the spent nuclear fuel that we have in storage around the country. Thank you very much, that's all I had to say today.

MR.

CAMERON:

Well, thank
you, Christopher, for those comments. And we're ready for the next speaker, Calvin.

OPERATOR: Yes, sir, and that speaker comes from Steven Sondheim. Your line is open.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. SONDHEIM: Hi, can you hear me?

MR. CAMERON: Yes, we can, Steven.

MR. SONDHEIM: Thank you. Thank you. I certainly beg to differ with the last person, my goodness. What I was going to say was that the canisters themselves are not adequate.

They can't be inspected, they can't be monitored, so if there starts to be a leak and there starts to be extra gas and an explosion, there's documentation that shows that if one of these explodes, it's almost got the Chernobyl amount of --

whatever, that's not the point.

The point is, you can't tell what's going on inside them. And you can't monitor them, you can't inspect them, and if there was a problem, you can't retrieve what's inside. Now, that's a problem onsite, where they are now. It's also a 10,000-times problem if you're going to put a bunch of these together. And if one of these exploded, a whole bunch would explode.

Plus, you've got the problem of transporting them.

There's many furniture manufacturers that won't ship expensive furniture on rail, because it vibrates and they're loose and they come apart at the end. It's just too vulnerable.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And I think the DEIS needs to take a significant look at whether or not -- what they would do if something started to leak and even answer the question, how can they tell if something starts to leak?

The -- I'm Steven Sondheim, I'm with the Sierra Club, I'm on our Nuclear Free team at the Sierra Club. I also have an aunt in Santa Fe, in the area.

The -- supposedly, these canisters are only validated for 40 years. Is there anything in the DEIS that says what they're going to do after 40 years?

So, those are my essential questions. If the previous speaker has documentation on all that, well, let's see it. I don't think so. And also, that's one hell of a reason, just to be mad at people, to bring something he won't want anyway. Come on.

Okay. Thank you very much.

MR. CAMERON: Okay. Thanks, Steven. And with that, we're going to take a break for 15 minutes.

So, Calvin, relax for 15. And we're going to come back at five minutes to 8:00 Eastern, five minutes to 6:00 Mountain Time. And we're going to start up again. So, thank you, we'll see you in 15 minutes.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 (Whereupon, the above-entitled matter went off the record at 7:41 p.m. and resumed at 7:55 p.m.)

MR.

CAMERON:

Well, good
evening, everybody, again. We're back and we're looking forward to the rest of the comments on the draft EIS.

And, Calvin, are you up there? Or out there?

OPERATOR: Yes, sir, I'm here.

MR. CAMERON: Okay. Well, good. Well, let's go to the next speaker and hear what they have to say.

OPERATOR: Yes, sir. Our next speaker comes from Kevin Kamps. Your line is open.

MR. KAMPS: Hello, thank you. My name --

MR. CAMERON: Hello, Kevin.

MR. KAMPS: -- is Kevin Kamps, yes, and I serve as Radioactive Waste Specialist at Beyond Nuclear and on the Board of Directors of Don't Waste Michigan, as well as an advisor to Citizens for Alternatives to Chemical Contamination.

And I mention all three groups because we are all official legal interveners against this Holtec proposal. In fact, Beyond Nuclear and Don't Waste Michigan and CACC are now in the second-highest court in the land, the D.C. Circuit Court of Appeals,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in opposition to this plan, for a variety of reasons.

And what I would like to focus on tonight are some anniversary dates. And as my Beyond Nuclear Board President, Kay Drey, points out, anniversary is too positive a term for most of these things I'm going to talk about, so we often refer to them as annual commemorations of very tragic and horrific events.

But I'll start with July 9, because that's today. So, July 9, 2002, the United States Senate voted to override the State of Nevada's veto of the Yucca Mountain dump.

The vote was 60 in favor of overriding and 39 opposed. It was the best we had ever done in a Senate vote against the Yucca dump. And a lot of those 39 votes against the override of Nevada's veto had to do with the transportation risks.

And I heard a previous speaker, I think it was Dave McCoy, mention that Yucca Mountain may have been ruled by the NRC to be out of scope in this proceeding, which if that's accurate, that is really absurd, because the NRC and Holtec itself have assumed that Yucca Mountain is the permanent dump site that justifies calling this Holtec proposal interim or temporary.

So, it's part and parcel a part of this

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Consolidated Interim Storage Facility proposal, so it can't be out of scope.

But I just wanted to point out that that transportation issue is what led 39 U.S. Senators to vote against the Yucca Mountain dump in 2002. One of them was Debbie Stabenow of Michigan, who's still serving.

And she actually reversed her position on the Yucca Mountain dump issue when she learned from us, because she was not informed of it by the nuclear industry lobbyists or the Department of Energy's so-called liaisons, who are lobbyists, she learned about it from us, that barge shipments are in fact proposed, or at least potential, on Lake Michigan.

Kelly Lundeen mentioned the number, 453, that we know of, going from Palisades in Michigan up to the Port of Muskegon, going from the Wisconsin reactors into the Port of Milwaukee.

If one of those shipments were to sink and release a fraction of its contents into Lake Michigan, it would be a disaster for the drinking water supply of 40 million people in eight states, two provinces, and a large number of Native American First Nations.

So, again, July 9, 2004, a couple years

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 later, we got a ruling back from the D.C. Circuit Court of Appeals, ruling that the 10,000-year regulatory time frame that the Environmental Protection Agency had set up at Yucca Mountain was illegal.

The case was brought by a coalition of five environmental groups, NIRS, Diane D'Arrigo is on the call tonight, Public Citizen, Citizen's Action Coalition of Indiana, Citizen Alert of Nevada, Nevada Nuclear Waste Task Force. Our coalition's oral arguments were made by Geoff Fettus of NRDC.

And that court ruling came out after a two-year review on July 9, 2004, two years to the day of the Yucca Mountain vote in the U.S. Senate. And the court ordered the EPA back to the drawing board regarding its Yucca Mountain dump regulations.

It took EPA four long years, but in 2008, EPA published its court-ordered rewrite of its Yucca dump regulations. And at that point, EPA recognized a million years of hazard associated with high level radioactive waste at Yucca Mountain, not 10,000 years. And even that million-year standard is lowball, because certain radioisotopes, like iodine-129, as an example, has a hazardous persistence of 157 million years, if not longer.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And the reason I bring up the long persistent hazard of irradiated nuclear fuel is, like folks have said on this call, it's very possible, probably even likely, that if this centralized so-called interim storage facility opens and operates in New Mexico that it will become de facto permanent surface storage, a parking lot dump in New Mexico, with nowhere to go.

And these containers are going to fail someday and they are going to release their contents into the environment unless they are replaced. And there's no plan for that. There's no dry transfer facility required by the NRC or planned by Holtec.

So, quickly, I'd like to move on to next week, July 16, which is a date of infamy in New Mexico and should be a date of infamy for the United States.

July 16, 1945, the first atomic blast in the history of Planet Earth, at Alamogordo, New Mexico.

And next

week, the Tularosa Basin Downwinders Consortium is planning its annual commemoration of this environmental injustice, this horrific assault on the health and well-being of New Mexicans downwind, including the Mescalero Apache, including Hispanics, including White ranchers, who have never even been acknowledged by the U.S. federal

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 government for their suffering, let alone compensated or provided healthcare.

So, that's next week. That'll be the 75th commemoration of Trinity, which of course was a practice blast for what happened at Nagasaki on August 9, and then, the uranium bomb that was dropped on Hiroshima on August 6. Those are 75 annual commemorations of the bomb. And the first bomb of all was dropped on New Mexico.

So, then, July 16, 1979 has been mentioned today, the Church Rock uranium mill tailing spill, perhaps --

MR. CAMERON: And Kevin, could you --

MR. KAMPS: -- the largest radiological release in U.S. history, that most people have never heard of. Navajo Dine --

MR. CAMERON: Kevin, could you --

MR. KAMPS: -- shepherds downstream --

MR. CAMERON: -- could you finish with --

MR. KAMPS: -- drink that water and use it for irrigation. And my last, final sentence will be that --

MR. CAMERON: Okay.

MR. KAMPS: -- in its ghoulish tone-deafness, the Nuclear Regulatory Commission itself

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 initiated the Holtec licensing proceeding on July 16, 2018. Thank you.

MR. CAMERON: Okay. Thank you. Thank you, Kevin. Calvin, who are we going to next?

OPERATOR: Next, we have Vina Colley.

Your line is open.

MR. CAMERON: Hi, we're ready to listen.

MS. COLLEY: Okay. You can hear me good?

MR. CAMERON: Yes, we can.

MS. COLLEY: Okay. This is Vina Colley, I'm President of Portsmouth/Piketon for Environmental Safety and Security and I co-chair National Nuclear Workers for Justice.

I'm a former worker from the Portsmouth Gaseous Diffusion plant in Piketon, Ohio. I'm also a whistleblower of them reprocessing reactor fuel at Piketon.

For years and years, our facility had been called a low level radioactive waste site. And this low level radioactive waste site, one of your speakers said he didn't know any victims, well, I'm one of the victims of low level radioactive waste with plutonium and neptunium and americium in it.

And of course, all this americium and neptunium is in a local school that they just had to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 shut down last year. So, there's many victims.

And plus, the low level waste, as they call it, has caused at least 21 to 22 different types of cancer for the workers at the Portsmouth Gaseous Diffusion plant, at the Paducah Gaseous Diffusion plant, Oak Ridge plant, New Mexico, and many other facilities around the United States. Workers are being compensated for their illnesses from working around low level, high level radioactive waste.

I'm concerned, and I want to thank you for letting me speak, I'm concerned that the NRC doesn't even have the authority over the radioactive component that's going to be shipped from state to state, because I think and what I've been told and what I've learned over 38 years fighting the local facility here is that the only one who has any say-so over the radiation component is the Department of Energy and the Department of Defense. So, your calculations would mean nothing to me if that's true.

The Ohio Health Department, the New Mexico Health Department, no one has jurisdiction over the radiation component of these facilities, other than the DOE and DOD.

It's devastating to listen, that you will have a telephone meeting with all these people,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 instead of a face-to-face meeting where we could sit down, where our representative can't be bought off by the big corporations, because the local people do not want any more of these sites in any state contaminated.

We need to stop producing nuclear weapons and focus more on cleaning these sites up and getting rid of this low level and high level waste, because the low level waste is also mixed in with the high level waste.

And in '86, they shut down a lot of landfills because the DOE facilities was sending this nuclear waste to the landfills. And so, one example was CECOS in Williamsburg, Ohio. They sent waste there, and they did this all over the country.

And so, until we find a real good solution and a real safe place, we need to stop the process right now, because it's all illegal, what you're doing.

And think about all the victims, and where's the government going to get the money to pay all of these people that's going to get sick like we are? We are sick and been sick and we have to fight for the compensation. So, 22 cancers has already been proven to come from radioactive and high level,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 low level radioactive waste.

I'm losing my voice, so I'm pretty much

-- I think I said what I've said. And we did have an accident in Piketon, Ohio in 1978 that was compared to Three Mile Island, but no one in this community or no one in the whole world had ever been told that this happened, other than a court record that was filed. So, so much criminal activity going on, site to site.

And then, our representatives, who I'm sure in November, there's going to be a big turnover, are giving you permission, because they think it's producing jobs. And all it's doing is fucking up all the environment that we live, that we can't even breathe in our own communities because of the pollution.

If somebody else is over the radioactive component of DOE, DOL, I would be glad for you to fax that to me or message me in an email, to vcolley@earthlink.net, because I've been trying for 30-some years to find out who really is in charge of the radioactive component that we're going to be packaging and shipping all over this world.

So, if you could give me that information, I would appreciate it, but I'm pretty

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 sure it's only the DOE and the DOL.

And even the EPA don't even have jurisdiction of these sites, because they only get slip samples of what the company gives them. The company takes the test, they give them a slip sample, and the EPA has no idea where those samples are coming from. This --

MR. CAMERON: I hope you --

MS. COLLEY: -- whole process --

MR.

CAMERON:

I hope you get the information that you are asking for and thank you for raising the jurisdictional issue with us. Thank you very much.

And we're going to move on to the next speaker. Thank you. And I believe Calvin is taking a break and we have Christine is our operator.

Christine, could you put the next speaker on for us, please?

OPERATOR: Thank you. The next speaker is Jeff Steinborn. Your line is open.

SENATOR STEINBORN: Thank you very much.

Good evening, everyone, it is State Senator Jeff Steinborn, calling you from Las Cruces, New Mexico, in Southeastern New Mexico.

And I am the past Chairman of the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Radioactive and Hazardous Material Interim Committee in the State of New Mexico, currently the Vice Chair of that committee, which has oversight responsibilities over all radioactive, hazardous materials issues in the state, which of course this would fall under. We had multiple hearings in the committee on Holtec. We visited with the Nuclear Regulatory Commission.

And so, having really looked at it and gotten much more knowledgeable, I have to say, and as a New Mexican, candidly, I'm really disillusioned and very offended, actually, by the process, the national process happening with this waste.

I do not view this as a national strategy, which I think our country needs to get back to figuring out a real national strategy for this waste. And in fact, it's being driven by private companies and by nuclear energy advocates, who want to keep churning out this waste, so that they can produce more of it. And national law seems to enable this lack of consent of a state. So, we can -- as New Mexicans, we're put in this situation.

But I just want to say at the outset that I heard one of my colleagues say, speak almost in third-person to how residents of Southeastern New

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Mexico feel about this, that they feel safe, yadda, yadda, yadda.

And I just want to say that there's many in Southeastern New Mexico who are very concerned about this proposal. And one local government very close to the facility, the Community of Jal passed a resolution against it.

I want to say, I believe that this process, that the limitations of COVID really preclude good interaction, challenges with technology, and the really full-throated discussion and dissent and support that should happen with this process, and not just in New Mexico, but nationally.

I want to echo those comments, to say this is way too serious to just do this in a couple conference calls, that this should be delayed and extended throughout the COVID era that we're in. It just -- this proposal demands that.

I think the deficiencies of the EIS are many, that it can't account for the fact that there is no permanent repository and that the EIS only accounts for the license period, even though there's no real future beyond that or that's it's like to be in the next, beyond that.

The EIS doesn't account for the risk to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the local communities that, according to Holtec, would be responsible for emergency response. And as we're hearing, that's not just in New Mexico, but all over the country. That this waste would not just ship by once, but possibly twice if it does go back out to a permanent repository.

The -- I'm not sure how the NRC can possibly attest to the safety of the canisters, when the life span of this facility, this license, exceeds the national experience with these canisters.

It certainly can't account for accidents, such as WIPP, that aren't the anticipated accidents, but the unanticipated accidents, such as we've seen in San Onofre, with the dropping of the canisters and the shim, the concerns over the shim being knocked loose, which are safety features in the canisters.

And I understand maybe the NRC is still reviewing that.

And that's just a few of them. As we've pointed out, we're talking about 10,000 canisters.

The EIS also can't possible accommodate the social justice issues, because it doesn't interview anyone proactively.

Finally, I've spoken to very high level experts in the government that are very concerned

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 about repackaging of this waste onsite, at this facility, when it is time to potentially ship it to a permanent repository or should there be an accident, that at that moment, there's going to be tremendous exposure.

Finally, I just want to say that there's been numerous communities in New Mexico and in Texas that have passed resolutions opposed to it, and I want to just briefly run that list, if I may, in closing.

And in New Mexico, close to 50 percent of the state's population have passed resolutions opposed to Holtec or about shipment of waste through the community, including the governor, including the land commissioner, the majority of our delegation, and including the City of Lake Arthur, Albuquerque, Jal, Bernalillo County, the City of Las Cruces, Santa Fe County, the City of Gallop, McKinley County, the City of Belen, the Church Rock Chapter of the Navajo Nation, the Navajo Nation Dine Uranium Remediation Advisory Commission, and of course, the All Pueblo Council of Governors, which represents quite a few.

In

Texas, encompassing 5.4 million people, resolutions have been passed from the City of San Antonio, the City of Midland, Midland County,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Bexar County, Dallas County, Nueces County, the City of Denton, the Midland Chamber of Commerce, and El Paso County, right next to me.

So, this is not a consent-based process.

And I would think we would all acknowledge, there's no such thing as infallibility. An accident will happen, it's not a matter of if, it's a matter of when. And this is simply not acceptable, to impose this risk on the people of the country and the state of New Mexico without a real national strategy.

And so, given those inherent limitations of the EIS, I would urge the NRC to hit the blinking red pause button on this project and recognize those deficiencies that ultimately should be deal-breakers at this time, until we have a real national strategy.

Thank you all for your time.

MR.

CAMERON:

Thank you for the information on the localities and thank you for joining us again. And, Christine, we're going to go on to the next speaker.

OPERATOR: The next speaker is Lorraine Villegas. Your line is open.

MS. VILLEGAS: Hello, can you guys hear me?

MR. CAMERON: Yes.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MS. VILLEGAS: Okay. Hello, thanks for letting me add my two cents here. I'm Lorraine Villegas from Hobbs, New Mexico, and I represent Lea County.

I've lived here for the majority of my life. I started kindergarten, graduated high school, and attended the local community college. And the state even has the highest Hispanic population and also the highest Spanish speakers in the nation.

And I currently work in the oil and gas industry and I've been sitting through these calls and through these meetings, listening to the politicians who supposedly represent us tell you guys, the NRC, over and over how much we want this project.

And I'm in this community daily, I work here, I live here, I have a big family here, lots of friends, and my circle of friends extends beyond a couple of politicians who have a couple of friends who have a few bright business ideas invested in this project.

And I'm here to let you know that we don't want this, we never wanted this, the only people who want this are the people who do have some attachments with business in it or the few that work in the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 industry.

And I know what you guys, Holtec has done in Camden, by promising jobs that they didn't actually get. And honestly, your only selling points are jobs and money, and let me tell you, money's not enough to convince me that this is a good idea.

Economic growth and diversifying the economy isn't working for me. You guys had a chance to, our politicians have had a chance to diversify the economy by possibly bringing in other industries, like legal recreational, medicinal, recreational cannabis, and you guys shut that down, but instead, you choose nuclear waste, which is definitely more of a threat than a plant is. And you shut that down, so who is this really going to benefit here? Because it isn't my community.

So, thank you for your interest, but this isn't it. I really appreciate it and I really appreciate all the politicians who have been working in support of this, because to me, it's been blatant that you support a company who has a known track record in corruption and for you to back that company and tell us that it's a great company just really explains a whole lot about what's going on here.

So, that's all I have to say, thank you,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 God bless you guys, God bless your families, and peace and love to all of you.

MR. CAMERON: Thank you. Thank you, Lorraine, for those blessings too. And, Christine, let's go to the next speaker.

OPERATOR: The next speaker is Marilyn Elie. Your line is open.

MS. ELIE: Thank you. I am Marilyn Elie.

I am a member, longstanding member, of the Indian Point Safe Energy Coalition. I live two and a half miles from Indian Point. Unit 2, half of the units there right now, has been turned off and we are looking at decommissioning by Holtec.

What I would like to say is that as we have looked at the company that Entergy, the owner of the plant, the license holder, would like to have take over, has been very eye-opening and very discouraging.

They're crooked. They were in court in Camden, New York for bribery. They were not permitted to work for the World Bank and many other places because of their illegal and crooked business practices.

These are not people that we want to have anything to do with decommissioning Indian Point or

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 transporting waste to a supposed temporary storage.

And what I really, the point I really want to make is that the NRC is complicit with the industry in this. There is no other way to look at it. You are not protecting the health and welfare of the people in our reactor community or the community where you wish to, and are really actively promoting, sending this high level radioactive waste to.

Because what's going to happen with your draft and your subsequent approval, we all know that's what will happen, Entergy and Holtec take it to the U.S. Congress and they say, look, the regulatory body has approved it, we really need you to change the law, the Atomic Energy Law, that prohibits, prohibits having short-term storage until we have a long-term place to put the waste, we'll just change the law and ship it on and everything will be fine, we'll have jobs and so on.

Well, it's that kind of superficial thinking and that kind of crooked and immoral thinking that has gotten us into this current location.

I don't live in the reactor community of Buchanan, but I do live, as I said, two and a half

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 miles from the plant and I am impacted by it with taxes, with jobs, and with everything else.

But also, with the immorality of our community contaminating another community and contaminating, transporting this across the country to a community of color, a community that is not wealthy and as mobilizing to say, we don't want it, and you want to do something against consent?

That was one of the first things in that blue ribbon report, a community must consent. You have no consent and you are complicit as an agency with a company that is immoral and crooked in order to foist this high level radioactive waste from my community to another, so that money can be made.

Now, there are people in my community that will say, wonderful, let's go with Holtec, they're going to make the waste go away. Well, there is no away. And certainly, New Mexico is not away, it is part of this country, those people need to be respected. Consent-based is not something that you have.

And that waste, which we use in this general region, the benefits of it, electricity was fleeting, the waste is forever. But our generalized, our regional community, had the benefit of that

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 plant. You can talk about the jobs, you can talk about the economy, nuclear power is not a job machine, it's an industry that is designed to make money for its stockholders.

And it did that and it stayed here until it could no longer make money and then it decided to leave. Well, that's American capitalism for you.

However, we have custody of the waste and it needs to stay here, not be transported to another community to contaminate that community, and it needs to be in something called rolling stewardship, which would have a permanent agency, a permanent, call it whatever you want, agency, committee, board, that would monitor it and make sure that it is safe.

Now, what are you going to do when it's safe? Because you have no provision for what will eventually happen, if somebody, if people make something, it will eventually have an accident, that's just the way of the world. So, there's no hot cell, there's no way to go back and re-cask, and the casks are not superior, they are inferior.

And a lot has been said, I'm not going to go into all the ways they're inferior, but they're not strong and they're not made to last the time that they need to say right there on that parking lot,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that slab of concrete where they're sitting now.

At least there, they're up above the river, they're in a relatively safe location from Indian Point, they're on the property, they can be monitored.

And to move them and to risk the damage to the casks and to the contamination to the community, to put them some place where they can and will be forgotten, Holtec is a company, it's not going to be here forever, what happens to the casks when Holtec goes out of business because it's convenient for them to declare a bankruptcy and those --

MR. CAMERON: Marilyn --

MS. ELIE: -- rusting casks are --

MR. CAMERON: -- thank you --

MS. ELIE: -- there. My last point would be that even though Holtec uses your agency and moving this waste out of our community as a selling point in order for them to get the contract, it's immoral and it's unethical.

And this kind of federal oversight for profit for a company is something that is not moral, it's not ethical, and there's just no effort, there's no evidence in what we're seeing in the EIS that any of this has ever even been considered, and it has to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 be.

MR.

CAMERON:

Marilyn, thank you.

Christine, who's next?

OPERATOR: The next speaker is John Buchser. Your line's open.

MR. BUCHSER: Thank you.

MR. CAMERON: Hi, John. Go ahead.

OPERATOR: I believe he had accidently disconnected from the call. Our next speaker is Carol Merrill. Your line is open.

MS. MERRILL: Hello, can you hear me?

MR. CAMERON: Yes, we can. Go ahead, Carol.

MS. MAYER: I'm a teacher, a librarian, and an author, and a citizen of New Mexico, and a member of CARD, Citizens for Alternatives to Radioactive Deposits or Dumping.

I signed up last time and could not get in to the webinar. I tried 12 times. You must have an in-person public forum for people who don't have computer access, maybe don't have computer skills.

Everyone needs to be a part of this discussion.

I'm just wondering why Holtec thought New Mexico would make a good dump for radioactive waste rods that would be radioactive and lethal for a

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 million years, why New Mexico?

Maybe someone thought, they can handle hot green chile, so they can deal with our hot mess from nuclear power plants on the East and West Coasts.

I don't want our state question to be red or green or plutonium with genetic disease and deformities for all at no extra charge.

What draws me to this situation is the experience with two friends. One who was seriously deformed by an innocent exposure to plutonium and he had to live an entire live, he's still living with the deformity, it's tragic. And another close friend who had a genetic disease as a result of a relative being exposed to serious radioactive emissions.

And I don't want to see that happen to anyone else. And I think of my friends in the southern part of New Mexico and almost weep, it is emotional to think of people being faced with this.

If this hot mess is profitable and safe, why get rid of it? Why wouldn't the people around the plant keep it? So, I don't think there's a truth here about the profitability and the safety.

When, not if, there is an accident, and there would be statistically speaking, who pays?

Holtec would likely go bankrupt and no insurance

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 company or government would cover their -- we have that evidence already in New Mexico for people who go begging, who are suffering from being close to any kind of emission.

Who replaces billions of dollars of revenue from oil, tourism, farming, not to mention priceless family legacies in the south of our state?

Holtec's become a verb, like Google has, go Google it. Don't let anyone Holtec you, meaning to lie and fool you and then, slowly torture and kill you and your grandchildren. You don't want that to happen, so don't go there.

Holtec could make better money, probably, designing really robust storage for this stuff, the hot mess, where it is now. I'm still trying to trace the rumor that I heard of the 19-inch thick canisters at Fukushima holding their rods through, successfully through earthquakes and tsunami without leakage.

Holtec should work on that.

It has been said we must trust science, well, science and engineering is what got us here in the first place, with the problem of these leaky messes.

So, if the waste would come to New Mexico, it would simply move a problem. It would not

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 solve the problem, it simply moves it. It is still a problem. Work on the problem where it is and don't just move it around, that doesn't help anyone. Thank you so much for this time.

MR. CAMERON: Thank you, Carol. We're going to go to John Buchser, can you put him on, Buchser?

MS. JAMERSON: Christine, could you put on John Buchser?

MR. CAMERON: Christine, are you still there?

OPERATOR: I am, sir. The line is open.

MR. BUCHSER: Hi, this is John Buchser.

MR. CAMERON: Oh, good. Hi, John.

MR. BUCHSER: Thanks for holding this virtual seminar, it's more interesting to have it in person, but COVID's a little restrictive. My own background is as a computer scientist, I've worked at various national labs here in New Mexico and state government.

And I'm a volunteer with the Sierra Club and have been working on this issue with Barbara Warren and others, making recommendations for the Club. I was pleased to see that the scoping document, that the DEIS is much improved as compared

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to that scoping doc.

It was good to see the impact evaluation, small, medium, and large. And I was glad to see that the full deployment was looked at for 20 years.

I was attending the last two years of the quarterly meetings of the Nuclear Waste Technical Review Board, lots of great collaborative research with many countries and good recommendations.

But I feel that the NRC is dismissing important recommendations and important baseline comparisons and, thus, failing to meet the protection of the public workers and the environment.

And then, in reading through this report, I see a number of things that I'll raise. On Page 2-21, on hardened on-site storage, it says that the NRC has not assessed this as it doesn't meet the purpose and the need.

Well, isn't the purpose and need of this to manage as safely as possible high level nuclear waste? Wouldn't HOSS reduce transport distance and, therefore, reduce the risk of damage to the casks in transport? The casks themselves have been tested for a 30-foot drop test.

But what if some accident occurs along the way, like even onsite specifically, unloading it,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 reloading it to go to permanent storage? What about damage in transport? Even the government's own number say there's going to be one damaged cask, but there's no means to address it.

What if a railroad car falls off a bridge that's in excess of 30-foot? As Barbara Warren pointed

out, there's lots of ways for the transportation system to fail.

And the connection to the Safety Evaluation Report, there should be a connection between that document. There's -- I do not agree with the NRC and Holtec's assumption that there will be no leaks, that's contrary to shipping that quantity of waste.

In looking at the geology of the area, the draft environmental statement goes into much more detail on the geology of the region, I appreciate that. However, there's some sort of inconsistencies.

On the plus side, I see that, on Page 426, that the Rustler Formation, which has the largest free water, is 335 meters down. That's probably okay. But the sinkhole analysis of the Delaware Basin, which is miles away and a different geology, on Page 328, what's the point? Are there other voids in there, like Carlsbad Caverns? That's

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a concern.

Next is, if a container does leak, it will probably contaminate Laguna Gatuna. And with maximum events of rainfall being on the order of 15 inches in September, is the record, hurricanes bring up huge amounts of rain, let's assume with global warming it could be double that, you're probably going to end with airborne contaminants all over the place and rather deep penetration of the soils.

What's the impact of alkaline soils on the casks? Oh, that's not important, that's a separate evaluation. That's absurd.

The emergency response, New Mexico has lots of volunteer fire departments. People, with this underground, deeply underground, at one of the radioactive waste meetings in Hobbs, I believe, the emergency people said, well, in a serious accident, the response is to run away, save yourself. That's may be fine for the responders, but what kind of mess does it leave.

Yucca Mountain's not big enough to hold all this stuff, and it's also much wetter than originally thought. And the dry transfer system, the lack of that is extremely concerning.

So, and finally, I think that we need to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 have folks in our schools that are learning about how to manage this problem that's going to chase after us for a million years or more.

If the appearance is that the NRC is based on political considerations to facilitate a vendor like

Holtec, rather than scientific considerations like the national laboratories and the Nuclear Waste Technical Review Board, it's going to be hard to get good new blood in the system to help solve these problems that are very complicated and will considerably exceed any experience mankind has had in developing systems. Thank you very much.

MR. CAMERON: Okay. Thank you, John.

And I'm sure the NRC would appreciate your specific comments, so I hope you follow up with that in a written comment. Thank you. And, Christine, could we have the next speaker?

OPERATOR: The next speaker is Katherine Williamson. Your line is open.

MS. WILLIAMSON: Oh, yes. This is Katherine Williamson, I am a concerned citizen and it's my first call. And I live in the Santa Fe County area, I live rather close to Lamy along the Highway 285 and 25 corridor.

I'm a person of science, I've worked as

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a nurse practitioner, I've worked in healthcare and science and research for 35 years at a large medical university. So, I do believe in science. And I also reviewed the draft of the EIS.

As much as I'm sure the scientific community for the Nuclear Commission has done a thorough job and they've really looked at the safety and transportation issues of nuclear waste across our country, I'm really concerned that the public environmental issues are not being well-represented.

And I have some confidence in their research and scientific input, but I thoroughly am aware that accidents happen. And in science and medicine and healthcare, accidents not only can happen, but they do happen.

And I live about one mile off of 285 and already along Highway 285, we're a north-south corridor for a lot of large trucks, oil tankers, nuclear waste tankers going from Los Alamos down to the Las Cruces area and Carlsbad Canyon.

And there's more and more trucks all the time, there are a lot of accidents that happen along here. And I also hear the Lamy, the Amtrak train horns go through twice a day. So, we're really close to the Amtrak railway as well.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And I'm really concerned there's going to be an accidents, that this isn't just in New Mexico, there are going to be accidents all across the country, it's just not a matter of if an accident will happen with some kind of nuclear waste, but when will it happen? And the question comes down to who do we trust? I mean, who do you trust?

Here in New Mexico, residents have already put up with Los Alamos and many accidents and nuclear waste spills that have contaminated the lands and the people and the -- I mean, there are a lot of areas in New Mexico that have downwinders that have experienced many forms of cancers, thyroid cancers, colon cancers, lung cancers.

These are not even being respected in the past and yet, we're asked here to respect some big corporation that comes in and that we think we should be able to trust something like Holtec. And they're a capitalist venture, they're not looking out for the health of the community or the health of the land or the health of Indigenous people or Hispanic people or White people.

So, I think you're really missing the mark on this and I don't know that you should realistically think that any of us trust this. We

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 don't want that nuclear waste. We don't want that in our communities. We don't want that stinking, putrid, cancer-causing nuclear waste to be dumped in our state of New Mexico.

We have a wonderful state, it might be a poor state, dangling a little bit of money in front of people's faces is always an enticement when you're in a point of low income, but we don't really want that, we don't need that. And my friends, my colleagues around this state, we don't want that at all.

So, I want you to hear that, we do not support this and we object totally. My name, again, is Katherine Williamson and I live in the Santa Fe County of New Mexico. Thank you.

MR. CAMERON: Thank you, Katherine, for taking the time to call in tonight. So, who do we have next, Christine?

OPERATOR: The next speaker is Nick Maxwell. Your line is open.

MR. MAXWELL: Can you hear me?

MR. CAMERON: Yes, we can.

MR. MAXWELL: My name is Nick Maxwell, resident of Lea County, inspector of public records, political meddler, entertainer, maybe least of all,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 watchdog of the Eddy-Lea Energy Alliance, which I will refer to as ELEA or the Energy Alliance.

I've lived in Lea County for a bit, I don't believe this project is safe and I don't believe Holtec will be a good partner for our area, and I have good reasons. Contrary to the ill-advised and influenced opinions of my local public officials, there is no widespread support in Lea County for Holtec's CISF.

First, let me thank you wonderful people standing against this injustice. I love you.

Second, NRC, I command the NRC public, give us public meetings for your draft EIS.

Instead of just cheerleading this project, as did my Senator Curtis, I actually got a substantive comment to make regarding the NRC's draft EIS. I may speak for more people than the Senator thinks he does.

Let's talk about it NRC, you've messed up some of this EIS. Let's look at Page 3-2 of your draft. You make the following claim under land ownership, which is most certainly inaccurate, and I quote, in April 2016, Holtec and ELEA executed a memorandum of agreement. I object. Did you hear that? I object.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 NRC is claiming that this memorandum of agreement was executed by ELEA. ELEA didn't execute this memorandum. This supposedly executed agreement can be found within the NRC's ADAMS database at Accession Number ML19081A, as apple, 079.

At Page 9 of the file, you will find the signature of only one director of the Energy Alliance. Specifically, John Heaton's signature, a former chairman of ELEA.

Now, you're going to find that ELEA bylaws require executed contracts to be signed by no less than two of its officers. Those ELEA bylaws are located with the NRC ADAMS database at Accession Number ML18255A, as apple, 234.

At the top paragraph of Page 93 in this file, you will find the following bylaw that applies to all contracts executed by ELEA, and I quote, all contracts shall be signed by both the chairperson or the vice chairperson and the secretary or the treasurer.

Once again, in brief, shall be signed by both. Both. Both means two. Where is my second signature? The second signature of the secretary or the treasurer of the Energy Alliance is not there.

Therefore, the contract that NRC alleges to be

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 executed is in fact not executed, according to the very bylaws which govern the Energy Alliance.

And listen up, y'all, this is where I speak about the exposed racketeering crime in my county. I showed up to one of these public meetings of ELEA in 2016 and I videotaped these boys footing a bill of $20,000 tax dollars for brokering a bribe.

With the unwitting help of Hobbs Mayor Sam Cobb, I discovered ELEA had spent tax money to broker a bribe, that they had Holtec kick back to them during a so-called competitive public bidding process wherein ELEA sold this public land to Holtec.

Directors of the Energy Alliance had solicited the kickback of a bribe, widely known as their highly touted 30 percent revenue-sharing deal.

Wait, wait, hold up, do we got the DOJ, the Department of Justice tapped into this line? Just kidding, boy.

Let me continue, where was I?

Oh, the bribe, a non-competitive price-fixing scheme, which artificially inflates future costs associated with this project. And it was pushed through my county's procurement office in a scheme concocted by John Heaton, Sam Cobb, and their friends at Holtec.

The sealed bid that Holtec pushed through

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 my county's procurement office peddled the idea that the U.S. Department of Energy was going to be paying this bill. Yes, the nation's taxpayers were going to foot the bill for a non-competitive 30 percent revenue-sharing bribe.

Are you boys on the line? You listening yet, John Waters, Heaton, Sam Cobb, Mr. Holtec? Are you hearing me? Your bribery, your price-fixing scheme has not gone unnoticed. I hope you don't think is funny, racketeering is a serious offense, boys. How's Gary King working out for you?

If y'all want to know more about the truth of the Energy Alliance, come to my website at www.wethefourth.org, that is written similar to we the people, but with fourth at the end, as in first, second, third, fourth, wethefourth.org.

A public petition is circulating in Lea County to convene a grand jury to investigate these organized white collar racketeering felons. We demand justice for these crimes. Maybe Holtec is going to have some business development positions open after the grand jury indicts the guilty. Jill, you've got this wonderful test case, check into it.

Am I on time?

MR. CAMERON: Yes, you're good. Thank

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you, Nick, for that information. Could you please just repeat the website you mentioned? And then, we're going to go to the next speaker.

MR.

MAXWELL:

I

will, www.wethefourth.org.

MR. CAMERON: Okay. I think we have it here, thank you. Thank you, Nick. Christine, who's next?

OPERATOR: The next speaker is Karen Shaughnessy. Your line is open.

MR. CAMERON: Karen? Karen, are you there?

OPERATOR: Please check your mute button, ma'am, or if you're on a speakerphone, lift up the handset.

MR. SHAUGHNESSY: Hello, this is Terrence Shaughnessy. Can you hear me?

MR. CAMERON: Okay. Yes, we can.

MR. SHAUGHNESSY: Oh, good, thanks, I'm glad I waited. I live in St. Paul, Minnesota and I'm part of a group of people that are strongly opposed to this action and the plans behind it.

And I think what I wanted to speak to is the stewardship that you folks on this Commission have as an obligation not only to the citizens of the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 country, but primarily to the environment. And not in contrast to corporate America.

I live near Minneapolis and as the world has seen in the last month, six weeks, things can get stood on their head pretty quickly. And I work in the spiritual world, I work with a lot of people from different spiritual traditions, from CEOs of major corporations to Indigenous people to people in various religious positions.

So, I speak from that perspective. And one of my maxims that I live by and that I believe deeply in is that change only happens on the margins.

And by that, I mean, when we're living in the comfort of the status quo, there's not a motivation to change.

And what happened in Minneapolis with the murder of George Floyd has rippled across the world and upset the status quo. The status quo is dominated by power structures.

And in this situation, I just want you to consider and think about how you may think that this is a rote process, you may think that this is pro forma for you in your role, it is not. It is a very serious obligation that you have to a very important issue.

And I think Black lives matter. I think

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 how we respond as a community to the COVID crisis and all the division that's shown up is just a prelude to the biggest issue in our time, which is global warming.

So, I want you to consider how there's a connection to what started in Minneapolis and what has blossomed and burgeoned as a justice issue across the world, to those that never thought it would happen, those that were disempowered never believed they'd have a voice.

And I want you to consider how the people that have spoken for these last hours were feeling disenfranchised and unable to be heard against the power of Holtec and other corporate interests. Don't take that for granted. Don't ignore the message of the disempowered against the powered, the people in power.

I'm not sure how else I can say that, but I just deeply believe your obligation is to be stewards and not to be beholden and speaking for, in some kind of a, again, pro forma way to those that are in power.

So, I really hope you can listen with your hearts and be open to this process from a different perspective and know that your obligation

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 is great and it's greater than the decision about nuclear waste. But I thank you for your time.

MR. CAMERON: Very, very thoughtful, Mr.

Shaughnessy. Could you spell your first name for us?

MR. SHAUGHNESSY: Terrence, T-E-R-R-E-N-C-E, and I'm from St. Paul, Minnesota.

MR. CAMERON: Okay, beautiful. Thank you. Thank you, Terrence.

MR. SHAUGHNESSY: Thank you.

MR. CAMERON: Christine, do we have another one?

OPERATOR: The next speaker is Teresa Seamster. Your line is open.

MS. SEAMSTER: Thank you. And thank you to the earlier speakers from San Onofre, your testimony and your ground observations were very informative. My name Teresa Seamster.

I'm a

member of the New Mexico Environmental Public Health Network, which has over 100 health professionals and public health and environmental agencies and organizations from throughout urban and rural New Mexico.

I'm also a resident in Los Vaqueros, which is located on Highway 285 South, the Holtec transportation connection between I-25 and I-40 in

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 New Mexico. This is a winding three-lane highway that's totally unsuited for oversized rigs needed to carry 200-ton proposed canisters through local rural traffic.

I have reviewed the DEIS and I attended the Holtec presentation that was made in 2018 before the state legislature, that Senator Jeff Steinborn referenced, the Committee on Radioactive and Hazardous Waste.

I think the NRC should carefully examine the statements that were made by Dr. Stefan Anton, the VP of Engineering and Licensing for Holtec. That testimony raised many red flags for residents on transportation routes and for those in New Mexico health and environmental organizations.

Dr. Anton characterized the Holtec site as a thousand acres of dry, stable land, 35 miles from the nearest town. He didn't mention the oil wells that are located on both sides of the Holtec site.

The land is not dry all year round, I think someone mentioned the nearby playas can get up to 15 inches in one monsoon event and can flood an area. It is not a guaranteed geologically stable area, as there are nearby oil wells mentioned already

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that are prone to heaving and creating sinkholes.

And the extent of those sinkholes really is not known.

Also, later in the testimony, instead of presenting any kind of real economic benefits to Eddy-Lea Counties, John Heaton mentioned that the total job increase would be 240 jobs over ten years, and that would dwindle to five full-time employees, which is not much.

Water supplies are critically short in the areas. The roads are two-lane rural highways.

The rail spur is really ancient and will need major upgrades if it can qualify for loading, transporting, and unloading these huge canisters.

Basically, what most of us came away from the hearing was that Holtec is really offering a thousand acres of undeveloped land and 500 silos and for this, it will receive $2.4 billion.

They have an unsecured promise that the U.S.

Department of Energy would take all responsibility for the transportation of this fuel and that the DOE would enter into a contract, which will require taking on the liability and funding for emergency preparedness and training in case of accidents or rollovers along tens of thousands of highway miles and railroad miles involving 10,000

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 shipments of high risk waste. That's a huge cost.

Don Hancock, who followed Dr. Anton's comments, is the Nuclear Waste Program Director for the Southwest Research and Information Center. And he really highlighted the health and safety risks to the legislature of long-distance transportation at this scale and long-term storage.

He also highlighted that Holtec stated they would reject and return all canisters with unacceptable external contamination. And external contamination really has not been addressed in the DEIS. This would give all local residents and those along the routes potential radioactive exposure twice from such said shipments if they were returned.

There's a long list of problems that was brought up at the interim committee hearing and in the public hearings since then. One of the most obvious is the remote location that's been selected.

This location is so far away from all the reactors that would be shipping their waste.

When Holtec's big advocate John Heaton was speaking, he touted the 23 facilities around the country that are looking at being decommissioned in the future. But he barely acknowledged the fact that there's 64 interim facilities that already exist in

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the U.S. Most or all of them are paired with a reactor facility and they will require this used nuclear fuel storage in the future.

So, clearly, a closer storage solution is better in terms of public health and safety, as well as it would be much lower in cost and less burden on the state and federal first responders, highway and transportation agencies, and local residents.

Finally, Don Hancock mentioned an existing private fuel storage facility in Tooele County, Utah, which was granted a 20-year license in 2016. That fuel storage facility has never been used, and that's due to the stiff opposition from the governor, the state legislature, the local and tribal governments, and the Utah citizens.

And I think that might serve as a cautionary tale for those who support this really disastrous time bomb of a project. Thank you.

MR. CAMERON: Thank you. Thank you, Teresa. Christine, could you put the next speaker on?

OPERATOR: The next speaker is Susan Skerman. Your line is open.

MS. SKERMAN: Hello, can you hear me?

MR. CAMERON: Yes.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MS. SKERMAN: Excellent. Thank you, Chip. Like Karen Hadden and Sean Marford mentioned, we can't see who from NRC is actually listening right now to our comments, which is a little unnerving.

Perhaps you all could take a photo of who's in the room and post it on the NRC's Facebook page and mention who is not pictured but participating by phone.

I wasn't able to get to all my comments last month, so I'd like to add a few now. Thanks so much to all the other commenters tonight.

The draft EIS is woefully inadequate because, in addition to what I said last time, it ignores that endangered and threatened species will be irrevocably harmed. Critical habitat of the dune sagebrush lizard and the lesser prairie chicken is in the project area.

And like Brendan Shaughnessy mentioned, archeologically sites will be irrevocably harmed.

The Laguna Plata Archeological Site is in the project area. Over 200 archeological sites have been identified, largely connected to the Jornada Mogollon people.

A Native American tribe has stated unequivocally that traditional cultural properties of

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 significance to the tribe will be affected if this project is approved. The Hopi Tribe has written a letter to the NRC stating that fact, which is available to the public on the NRC website.

Moving forward with the project in spite of the Hopi Tribe's unequivocal objections is a clear violation of environmental justice and international law that states Indigenous peoples should have free, prior, and informed consent before projects move forward that impact their land or traditional cultural properties.

The site ELEA wants Holtec to contaminate with deadly radioactive waste is a special territory of the Hopi Tribe, as well as the Mescalero Apache.

For the draft EIS to claim no disproportionate impacts will affect People of Color is inaccurate and worse, it's gaslighting and it's a former of settler colonial violence on Indigenous peoples.

Holtec is in more trouble. Like Cindy Rae Wheeler mentioned earlier, it was revealed since the last NRC webinar that Holtec International is actually under criminal investigation by the New Jersey Economic Development Authority stemming from their falsification of their application for tax breaks for their factory in Camden.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 They said no to the question that, had they ever been banned from bidding on federal contracts? We know Holtec was banned in 2010 for bribing the Tennessee Valley Authority, or the TVA, to get a contract.

Holtec put up a TVA employee at the Trump Taj Mahal Hotel in Atlantic City for him and his wife and paid $50,000 in bribes. And they lied on their application for tax breaks in New Jersey and they got caught.

Holtec International has a track record of corruption and we cannot trust what they put on their application for interim storage in New Mexico, neither their safety evaluation or their environmental report.

It's time to stop making more nuclear waste. Nuclear energy is dirty energy, not clean energy. NRC should stop approving more nuclear reactors and completely refocus energies on truly protecting people and the environment, by storing the waste that current exists in hardened on-site storage, or HOSS.

Finally, racist monuments are coming down across this country. We do not consent to Holtec and ELEA building a racist monument made of nuclear waste

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in New Mexico. Thank you.

MR. CAMERON: Okay, thank you. Thank you, Susan, for those comments.

OPERATOR: And --

MR. CAMERON: Christine -- oh, Calvin's back? Okay. Welcome back, Calvin.

OPERATOR: Thank you. Our next commenter comes from Peter Clark. Your line is open.

MR. CLARK: Yes, thank you. You said my name, I'm Peter Clark. My family and I have lived in Albuquerque since 2005. Every day, we acknowledge that we continue to occupy stolen land taken by force, taken by

genocide, and significant to this proceeding, taken by colonial laws.

And I would harken back to what the previous caller just mentioned, free, prior, and informed consent, and recommend that the NRC consult the United Nation's Declaration on the Rights of Indigenous Peoples and the OAS' similar declaration of the rights of Indigenous peoples.

I have read the DEIS. I have -- my experience, 30 years of experience in transportation field, including work in rail, work in aviation, and commercial trucking of hazardous materials as a licensed driver. I have developed safety management

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 systems, I have extensive training in human factors and accidents.

And I'm pretty much dumbfounded, I have no doubt that you, the NRC, will rubberstamp your approval of this license. This entire process, from beginning a couple years ago, has been a dog and pony show, where the NRC will be able to check off tasks on your path to approve this license. I've seen that time and again.

And shame on the NRC, shame on the ASLB for denying intervener standing to local groups and individuals seeking to present their contentions.

Your process is honed to silence opposition, while you pretend to be inclusive.

Shame on the NRC for continuing this process at this time of unprecedented national crisis. By pushing through with this licensing project at this time, when people are focused on protecting themselves and their relatives from this deadly virus, when nearly 135,000 people just in this nation have died, you put an undue burden on the poorest among the nation, who are always hardest hit by these circumstances. Hardest hit by COVID, certainly.

For the NRC to expect their participation

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 or anyone's participation in this poorly run telephone call and in the larger process just displays your hubris and your arrogance. And it shows your privilege.

I think in closing, I'd like to say that I grew up near the Oyster Creek nuclear reactor for my first 17 years of my life. I used to fish in the warm waters of the discharge for stripers, as many people there do. I don't want my waste from New Jersey to be dumped on New Mexico.

Our governor, our elected members of Congress, the folks that have been on these calls have stated our opposition and we don't consent.

Shame on the NRC for publishing this whitewash of a DEIS. That's all I have to say.

MR. CAMERON: Thank you, that was Peter Clark. And, Calvin, who is next?

OPERATOR: Next, we have Missi Currier.

Your line is open.

MS. CURRIER: Good evening, everyone. My name is Missi Currier and I work for the Economic Development Corporation of Lea County. I am proud to live in Lea County and I'm also from Eddy County.

With that in mind, my comments tonight represent my Board of Directors for the EDCLC. We

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 do support this project and appreciate the work that the NRC has done in ensuring that this project will be safe and also allowing us to further diversify our economy.

Of course, there have been comments that said that this is not an opportunity for diversification. We feel that it is. We feel that it will bring additional jobs and additional revenue to the state of New Mexico, in both a healthy and safe manner.

We appreciate the work that the NRC has done. We will follow this up with written comments.

And thank you for your time this evening and for hosting both this listening session and the one in June.

MR. CAMERON: Well, thanks, Missi. Thank you very much.

MS. CURRIER: Thank you.

MR. CAMERON: Okay, good. Good. Thanks, Missi. Calvin, who's next?

OPERATOR: Next, we have Bianca Rivera.

Your line is open.

MS. RIVERA: Hello, can you hear me?

MR. CAMERON: Yes, we can.

MS. RIVERA: Hi. Hi, I'm Bianca Rivera

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and I'm Latinx and Chicanx. Many of my ancestors are from the United States and they were prosecuted and run out to Mexico. They lost their homes, culture, and family.

The reason I bring this up is because this project is a continued form of colonialism, genocide, and environmental racism and we do not consent. Our land is sacred from root to stone and you have no right to decide who is disposable, who can be destroyed, and who can be used as disposal.

We do not want this waste. What we want are reparations for the people who are still suffering from past nuclear projects. Clean New Mexico, don't continue to destroy it, we are not a wasteland. (Non-English language spoken.) Thank you.

MR. CAMERON: All right, thank you. Thank you very much, Bianca. Calvin, who's next?

OPERATOR: Next, we have Rose Gardner.

Your line is open.

MS. GARDNER: Okay. Can you hear me okay?

MR. CAMERON: Yes, we can.

MS. GARDNER: Okay, thank you. Hey, guys, this is Rose Gardner, from Eunice, New Mexico. I live in Lea County.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And even though a lot of the speakers had, and in the previous call, had shown all this support for this Holtec venture, I find some of them kind of hanging back. I don't see the support, I don't hear it in their voice. I don't see that they're enamored of this wonderful project anymore.

And so, that gives me a little hope that at least some of these important issues are sinking in.

Here in Lea County where I live, we are over 51 percent Hispanic. Therefore -- that speaks for itself. We are an important part of this state and what we want is a good, safe place to live, to raise our children and grandchildren, and this isn't the way to do it, folks.

Dumping nuclear waste from all around the country at the Holtec site, the Laguna Gatuna area, is not right, it's unjust. Don't burden New Mexico with this stuff.

You people out there in these reactor communities have lived with it for a while, you know it's bad, why would you even consider taking this junk from where you live and sending it over here, where we don't deserve this? So, I feel strongly about it. I feel that the NRC is not looking at this in a way that is conducive to public honesty and

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 opinion.

You haven't heard too many people on the private side speak up have you? It's been in the newspapers, but how many people get the local newspaper? I think here in Eunice, we might have a subscription of 600 people. There's 2700 people that live here.

And I've talked to people this week, yes, they see it, so what? They're not going to participate. This thing started at 3:00 in the afternoon my time. Those people that are out there working and trying to make a living are busy.

We must have a public meeting at a reasonable hours so that people can attend. It's the right thing to do. Give us a chance to speak up and look at you and look at these supporters that support this poison coming to where I live.

I have a real problem with the Holtec transportation and storage system. Now, you might say, Holtec doesn't have a transportation system.

Well, sure they do. They're buying all these reactors and trying to decommission these sites, that's theirs. That makes it a Holtec problem.

Transportation, they're going to bring it on the rails, they better be ready to bring it here

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 safely, follow the guidelines at WIPP. Those are very stringent, and even so, WIPP blew up. It cost

$2 billion and they're still wanting more money. Why don't you ask them?

We have to consider the earthquakes in this area. Just ten days ago, we had a 2.71 just outside of Lovington and Hobbs, New Mexico. It's no so very far from the site. These might be minor, they might be part of the fracking business, I don't know. But the thing is, they're there, they're real and they need to be looked at.

Finally, my concern too is that this doesn't address anything regarding climate change.

It's blasted hot here today, 106 degrees, and we're expecting higher figures later in the next few days.

Consider this already hot container, sitting in the ground, bubbling, and people say, oh, there's no fluid or liquid in there, nevertheless, that stuff is hot coming out and it's going to be sitting in the ground, decaying, and at some point, I read, it even gets hotter.

So, I say, this is all wrong for us, let's find a permanent solution for it. Let's work together, why can't we work together? These people want to make money. The local politicians want to

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 make money. Well, let's make some money then, let's find a good place for this, let's find a consenting community that is willing to sacrifice their health MR. CAMERON: Thank you --

MS. GARDNER: -- and put it in their backyard. I'm not willing to do that. There's a ranch right there at the site, I refuse to allow them to get run over by Holtec. I refuse to sit back --

MR. CAMERON: Rose, thank you --

MS. GARDNER: -- and let this company take over New Mexico, and that's what will happen. If Holtec comes into my state, they're going to be running the show. And I'm tired of it. I'm tired of seeing big business get its way and the little people --

MR. CAMERON: Rose, I'm going to --

MS. GARDNER: -- the People of Color in New Mexico --

MR. CAMERON: -- have to ask you --

MS. GARDNER: -- get the burden of it.

MR. CAMERON: -- to stop.

MS. GARDNER: Thank you so much, Chip, for listening. And again, I oppose Holtec and their project. And again, thank you so much.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Okay. That was Rose Gardner, thank you. And, Calvin, who's next?

OPERATOR: Yes, our final comment comes from Nicholas King. Your line is open.

MR. KING: Yes, thank you. My name is Nicholas King and I'm pastor at the Carlsbad Mennonite Church here, a few miles from where they're planning on putting this. I appreciate the extensive analysis of this DEIS, certainly a lot there.

But one glaring omission I find is on the long-term issues of this, that they look long-term at 40 years or maybe even 120 years. But as most of us know, that's not a very long time. Anyhow, if there's no permanent repository for this, then it's going to stay there and it's going to be permanently put in a temporary place. And that is not really well addressed in this whole issue.

And although it may be good for us economically now, what about the legacy to our grandkids and the civilizations that follow? It's a short-term gain for a long-term problem. And the benefits we're looking at are maybe ten, maybe 40 years, but then, what are the benefits? It's only going to be a problem.

What are people going to say in a hundred

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 years when this is crumbling and the casks are deteriorating and there's leaks and there's no funding to fix it? Won't they be proud of this decision we're making now?

This is going to way outlast our government and our civilization, and then who's going to fund it? Who's going to be responsible? We need to cancel this proposal and make something that's a permanent solution. This band-aid solution is not right.

And I base this on two things. First of all, private enterprise and future funding. That, first, Holtec is a private company and will, like any company, shut down when things are not profitable or when they run into major problems, that's the way we function. It's not if, but when.

And when Holtec folds, who will hold the bag? We here in Carlsbad have that same experience with the WIPP that went belly-up and the taxpayers had to come in and pay $43 million to clean up this private industry problem.

We're dealing with that in the oil industry, where if an oil company folds and walks away, who is going to foot the bill to clean that up and cap those wells? In this case, it would be a

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 whole lot more expensive to move this whole waste dump.

Second is the funding thing, which is really always plays based on political whim. When Holtec walks away, there will be no political incentive for the rest of the nation to help New Mexico clean this mess up, it will be our problem, it's in our backyard, and if there's not a functional government at that time, it will only be ours here.

We have elected officials that look after the interests of their own area. And we only have two senators and one representative in Congress. And besides that, looking at the current instability of our government, how do we depend on funding for the next 40 or a hundred or a thousand or who knows how many years to come to deal with this toxic mess?

Who's going to take care of it?

We owe it to our great-grandkids to deal with our mess, it's ours and we need to do that permanently now, and not just a stopgap measure with a dead end, temporary fix.

There are just a short-term jobs for a few now, that would be true, there would be a few jobs. But the big money goes to Holtec. They're the ones that win.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 But there's inherently long-term problems for us when they fold and when they decide they don't want to deal with it. Our politicians, they've been sold this shortsighted bill of goods, but there's certainly been no voting or referendum on this locally.

The only meetings we've had on that in this area is some that the group that I was involved with put together, Citizens with Questions, and that was just one or two meetings. But the government has never had any meetings. There has been no voting, no referendum, but yet they say that everybody supports it, just because they've been sold that bill of good.

And of course, as you know how politics work in small towns, there's always the pressure to go along to get along. So, nobody wants to rock the boat if somebody comes up with an idea. But I don't really know that many other people that support this.

So, I ask you to deny this license for the good of all and for our posterity and to find something permanent, like WIPP, a site that is done, and we have taken care of our responsibilities in this generation, instead of kicking the can down the road to future generations.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CAMERON: Okay, thank you.

MR. KING: If we become the temporary nuclear dump of America, that will sabotage any incentive for other investment to come to this area.

Wouldn't you really like to bring your businesses to the nuclear waste dump of America?

And if that happens, we will permanently become the dump of America for thousands of years to come. Please --

MR. CAMERON: Thank you.

MR. KING: -- this is God's creation, don't desecrate it this way with short-term solutions to long-term problems. Thank you.

MR. CAMERON: Okay. Thank you, Pastor King. And thank all of you for comments and for courtesy. And thank you, Calvin, and thank Christine for us.

And I'm going to turn this over to our senior NRC official, who is John Tappert, the Division Director. John, you want to close off for us, please?

MR. TAPPERT: Yes. Thanks for that, Chip.

I just want to thank everyone for taking time out of their day to share your thoughts and comments with us. We will transcribe them and we'll reflect on

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 them as we're developing the final Environment Impact Statement. So, thanks again, I wish you a pleasant rest of your evening and be safe.

MR. CAMERON: Thank you, John.

(Whereupon, the above-entitled went off the record at 9:25 p.m.)